Informe de GAO Sobre La Asistencia de FEMA Tras Los Huracanes Irma y María

United States Government Accountability Office
Report to Congressional Requesters
PUERTO RICO
February 2020
DISASTER
RECOVERY
FEMA Actions
Needed to Strengthen
Project Cost
Estimation and
Awareness of
Program Guidance
GAO-20-221
February 2020
PUERTO RICO DISASTER RECOVERY

FEMA Actions Needed to Strengthen Project Cost
Estimation and Awareness of Program Guidance
Highlights of GAO-20-221, a report to
congressional requesters
Why GAO Did This Study What GAO Found

In September 2017, two major As of September 30, 2019, the Federal Emeregency Management Agency
hurricanes—Irma and Maria—struck (FEMA) had obligated nearly $6 billion in Public Assistance grants to Puerto Rico
Puerto Rico, destroying roads and for 1,558 projects since the September 2017 hurricanes. Of this $6 billion, $5.1
buildings among other things. Puerto
Rico estimates that $132 billion will be billion was obligated for emergency work projects such as debris removal and
needed to repair and reconstruct temporary power restoration. However, FEMA and Puerto Rico faced challenges
infrastructure and services through in developing long-term, permanent work projects under the Public Assistance
2028. FEMA is the lead federal agency program. The large number of damaged sites and delays in establishing cost
responsible for assisting Puerto Rico to estimation guidance specific to Puerto Rico have also presented challenges to
recover from these disasters. FEMA developing projects, according to FEMA and Puerto Rico officials. Both parties
administers the Public Assistance must agree to fixed cost estimates for these projects before work can begin.
program in partnership with Puerto
Rico to provide funds to rebuild FEMA and Puerto Rico had approved fixed cost estimates for 19 projects as of
damaged infrastructure and restore September 2019, out of 9,344 damaged sites in Puerto Rico, such as schools,
services. GAO was asked to review hospitals, and roads. FEMA and Puerto Rico have recently taken actions,
federal recovery efforts in Puerto Rico. including extending the deadline for fixed cost estimates, to address these
In this report, GAO examines, among challenges. However, it is too soon to assess the impact of these actions.
other things, (1) the status of FEMA FEMA has adapted its Public Assistance cost estimating guidance to accurately
Public Assistance program funding and
any challenges in implementing the
reflect costs in Puerto Rico but could improve the guidance to further enhance its
program, (2) the extent to which Public reliability. GAO found that FEMA’s guidance substantially or fully met best
Assistance cost estimating guidance practices for nine of 12 steps included in the GAO Cost Estimating and
addresses conditions in Puerto Rico Assessment Guide, such as documenting and defining the purpose of the
and aligns with best practices, and (3) estimate. However, FEMA could improve the guidance in three areas, including
the extent to which FEMA has analyzing risks and future uncertainties that could affect these estimates.
developed policies and guidance for
the program and any challenges with Hurricane Damage to a School in Puerto Rico, March 2019
these policies and guidance. GAO
reviewed FEMA’s cost estimation
guidance as well as documentation
and data on the Public Assistance
program through September 2019.
GAO conducted site visits to Puerto
Rico and interviewed FEMA and
Puerto Rico government officials
regarding the status of recovery efforts.
What GAO Recommends
GAO recommends that FEMA (1)
revise its cost estimating guidance for
Public Assistance to more fully adhere
to best practices and, (2) develop a
FEMA has developed Public Assistance policies and guidance to respond to
repository of current applicable Public
complex recovery conditions in Puerto Rico. However, Puerto Rico government
Assistance guidance available to all
relevant recovery partners in Puerto
officials GAO spoke with stated that they were not always certain about how to
Rico. The Department of Homeland proceed in accordance with FEMA policy because they did not consistently
Security concurred with these understand what guidance was in effect. Further, FEMA does not maintain a
recommendations. repository of Public Assistance guidance available to all recovery partners that
includes current applicable guidance. Without real time access to current
View GAO-20-221. For more information, applicable guidance, recovery partners risk using guidance that has been revised
contact Chris Currie at (404) 679-1875 or
curriec@gao.gov or replaced.
United States Government Accountability Office

Contents
Letter 1
Background 6
FEMA Obligated Nearly $6 Billion for Public Assistance in Puerto
Rico as of September 2019, but FEMA and Puerto Rico Face
Significant Challenges in Developing Projects 14
FEMA Has Adapted Cost Estimating Guidance to Specific
Conditions in Puerto Rico, but Could Take Further Action to
Fully Align the Guidance with Best Practices 20
FEMA Has Developed Public Assistance Program Policies and
Guidance over Time for Puerto Rico, but Recovery Partners
Reported Challenges 26
Puerto Rico and FEMA Have Structures in Place to Manage and
Oversee Public Assistance Funding and FEMA Has Instituted
Additional Controls to Mitigate Risk 30
Conclusions 35
Recommendations for Executive Action 35
Agency Comments and Our Evaluation 35
Appendix I The Status of Public Assistance Program Funding in Puerto Rico 40
Appendix II Summary of GAO’s Assessment of the Federal Emergency

Management Agency’s (FEMA) Cost Estimating Policies and
Guidance 44
Appendix III Comments from the Department of Homeland Security 49
Appendix IV Comments from the Commonwealth of Puerto Rico 53
Appendix V GAO Contact and Staff Acknowledgments 55
GAO Related Products 56
Page i GAO-20-221 Puerto Rico Disaster Recovery

Tables
Table 1: Federal Emergency Management Agency’s (FEMA)
Public Assistance Obligations to Puerto Rico and
Expenditures for Hurricanes Irma and Maria by Category
of Work as of September 30, 2019 16
Table 2: Assessment of Federal Emergency Management
Agency’s (FEMA) Cost Estimating Guidance for Public
Assistance Compared to Cost Estimating Best Practices
Identified in GAO’s Cost Estimating and Assessment
Guide 45
Figures
Figure 1: The Paths of Hurricanes Irma and Maria 7
Figure 2: Federal Emergency Management Agency (FEMA’s)
Public Assistance Program Categories of Work 9
Figure 3: Entities Involved in Implementing Federal Emergency
Management Agency (FEMA’s) Public Assistance
Program in Puerto Rico 10
Figure 4: Standard Public Assistance and Alternative Procedures
for the Federal Emergency Management Agency’s
(FEMA) Public Assistance in Puerto Rico 12
Figure 5: Federal Emergency Management Agency (FEMA) Public
Assistance Obligations in Puerto Rico as of September
30, 2019 15
Figure 6: Damaged Sports Complex in Caguas, Puerto Rico 17
Figure 7: GAO Assessment of Federal Emergency Management
Agency (FEMA) Cost Estimating Guidance for Public
Assistance Projects Compared to the 12 Steps for
Developing a Reliable and Valid Cost Estimate 22
Figure 8: Collapsed Segment of Road near Maricao, Puerto Rico,
September 2018 42
Figure 9: Damaged School Building in San Juan, Puerto Rico,
March 2019 43
Page ii GAO-20-221 Puerto Rico Disaster Recovery

Abbreviations
Central Recovery Office Central Office for Recovery, Reconstruction,

and Resilience
DHS Department of Homeland Security
DRF Disaster Relief Fund
FEMA Federal Emergency Management Agency
GAO Cost Guide GAO’s Cost Estimating and Assessment
Guide
Management Guide Disaster Recovery Federal Funds
Management Guide
NOAA National Oceanic and Atmospheric
Administration
RAND RAND Corporation
SOP FEMA’s Standard Operating Procedures for
Alternative Procedures
Stafford Act Robert T. Stafford Disaster Relief and
Emergency Assistance Act
Supplemental Relief Act Additional Supplemental Appropriations for
Disaster Relief Act of 2019
This is a work of the U.S. government and is not subject to copyright protection in the
United States. The published product may be reproduced and distributed in its entirety
without further permission from GAO. However, because this work may contain
copyrighted images or other material, permission from the copyright holder may be
necessary if you wish to reproduce this material separately.
Page iii GAO-20-221 Puerto Rico Disaster Recovery

Letter
441 G St. N.W.

Washington, DC 20548
February 5, 2020
Congressional Requesters
In a span of 14 days in September 2017, two major hurricanes—Irma and

Maria—struck Puerto Rico causing billions of dollars in damage to its
infrastructure, housing, and economy. 1 In its recovery plan, Puerto Rico
estimates that $132 billion in funding from 2018 through 2028 will be
needed to repair and reconstruct the infrastructure damaged by the
hurricanes, exacerbating an already difficult financial situation in Puerto
Rico, which had been operating under severe fiscal constraints prior to
the storms. 2 Estimating the costs to repair or replace damaged
infrastructure is an important task to determine federal funding needed to
support Puerto Rico’s recovery.
The Federal Emergency Management Agency (FEMA)—a component of

the Department of Homeland Security (DHS)—is the lead federal agency
responsible for assisting Puerto Rico as it recovers from these natural
disasters. 3 Among other responsibilities, FEMA administers the Public
Assistance program in partnership with the government of Puerto Rico,
including officials from various levels of government who work together as
partners in the recovery, providing grant funding for a wide range of
eligible response and recovery activities. The Public Assistance program
provides funding for debris removal efforts; life-saving emergency
protective measures; and the repair or replacement of disaster-damaged
publicly-owned facilities, roads and bridges, electrical utilities, among
other activities.
1
The National Oceanic and Atmospheric Administration (NOAA) measures hurricanes on
a scale from 1 to 5 with a Category 1 being the least intense and a Category 5 being the
most intense. NOAA defines a Category 4 hurricane as one with winds above 130 miles
per hour but less than 157 miles per hour. Hurricane Maria made landfall on Puerto Rico
as a Category 4 hurricane.
2
In fiscal year 2016, the last year for which audited financial statements are available at
the time of our 2019 review of Puerto Rico’s public debt, total public debt outstanding
stands at $65.2 billion. Puerto Rico’s total public debt outstanding increased continuously
between fiscal years 2005 and 2014, prior to a default in 2015. Puerto Rico is in the
process of restructuring its outstanding debt. See GAO, U.S. Territories: Public Debt
Outlook – 2019 Update, GAO-19-525 (Washington, D.C.: June 28, 2019).
3
See 6 U.S.C. § 313.
Page 1 GAO-20-221 Puerto Rico Disaster Recovery

On November 2, 2017, Amendment 5 to the president’s disaster
declaration for Hurricane Maria imposed a number of grant conditions,
including that FEMA must obligate all large project funding for Public
Assistance permanent work through alternative procedures as authorized
by the Sandy Recovery Improvement Act of 2013. 4 The stated goals of
the alternative procedures are to reduce costs to the federal government,
increase flexibility in the administration of the Public Assistance program,
expedite the provision of assistance under the program, and provide
financial incentives to recipients of the program for the timely and cost-
effective completion of projects. The alternative procedures also require
that FEMA and Puerto Rico develop cost estimates before work can
begin on large Public Assistance permanent work projects.
We have previously reported on federal disaster response and recovery

efforts in Puerto Rico. For example, in September 2018, we reported on
our observations of FEMA’s response to hurricanes Irma and Maria in
Puerto Rico, among other impacted areas. In March 2019, we reported on
the status of FEMA’s Public Assistance program in Puerto Rico, including
FEMA’s obligations and expenditures in Puerto Rico, and initial
challenges with the recovery process. 5
You asked us to review the federal government’s response and recovery

efforts related to the 2017 hurricanes. In this report, we examine: (1) the
4
See 82 Fed. Reg. 53,514-01 (Nov. 16, 2017). The Sandy Recovery Improvement Act of
2013 amended the Stafford Act by adding Section 428, which authorized FEMA to
approve Public Assistance program projects under the alternative procedures provided by
that section for any presidentially-declared major disaster or emergency. Pub. L. No. 113-
2, div. B, § 1102(2), 127 Stat. 39, amending Pub. L. No. 93-288, tit. IV, § 428 (codified at
42 U.S.C. § 5189f).
5
GAO, 2017 Hurricanes and Wildfires: Initial Observations on the Federal Response and
Key Recovery Challenges, GAO-18-472 (Washington, D.C.: September 4, 2017). GAO,
Puerto Rico Hurricanes: Status of FEMA Funding, Oversight, and Recovery Challenges,
GAO-19-256 (Washington, D.C.: March 14, 2019). Further, we testified on four occasions
between June 2019 and October 2019, regarding our observations on Puerto Rico’s plans
for using the alternative procedures program and challenges with program
implementation. GAO, Emergency Management: FEMA Has Made Progress, but
Challenges and Future Risks Highlight Imperative for Further Improvements,
GAO-19-594T (Washington, D.C.: June 12, 2019). GAO, Emergency Management: FEMA
Has Made Progress, but Challenges and Future Risks Highlight Imperative for Further
Improvements, GAO-19-617T (Washington, D.C.: June 25, 2019). GAO, Emergency
Management: FEMA’s Disaster Recovery Efforts in Puerto Rico and the U.S. Virgin
Islands, GAO-19-662T (Washington, D.C.: July 11, 2019). GAO, Disaster Recovery:
Recent Disasters Highlight Progress and Challenges, GAO-20-183T (Washington, D.C.:
October 22, 2019). For other relevant reports, see the Related GAO Products page.

status of FEMA’s Public Assistance funding in Puerto Rico and any
challenges FEMA and Puerto Rico face in developing Public Assistance
projects; (2) the extent to which Public Assistance cost estimating
guidance addresses specific conditions in Puerto Rico and aligns with
best practices for cost estimating; (3) the extent to which FEMA has
developed policies and guidance for the Public Assistance program in
Puerto Rico and any challenges recovery partners faced with these
polices and guidance; and (4) the structures Puerto Rico and FEMA have
put in place to manage and oversee Public Assistance program funding.
To address these objectives, we reviewed relevant laws and FEMA Public

Assistance grant program guidance, including the April 2018 Public
Assistance Program and Policy Guide, and the April 2018 and September
2019 revised Public Assistance Alternative Procedures Permanent Work
Guide for Puerto Rico. We also observed the data systems FEMA uses to
develop, manage, and oversee individual projects. These include the
Emergency Management Mission Integrated Environment and the
Integrated Financial Management Information System. We interviewed
officials from FEMA headquarters, as well as officials from FEMA Region
II, the FEMA regional office with oversight for Puerto Rico. 6 Further, in
May, August, and September of 2018, and March of 2019, we conducted
site visits to Puerto Rico to observe hurricane-damaged areas and
interview relevant FEMA and Puerto Rico government officials. These site
visits were not generalizable to all damaged areas across Puerto Rico,
but provided important context about the status of recovery efforts.
To assess the status of Public Assistance program funding in Puerto

Rico, we obtained and analyzed data on FEMA’s obligations and Puerto
Rico’s expenditures from September 2017 through September 30, 2019,
6
FEMA Region II is responsible for the states of New Jersey and New York, the
Commonwealth of Puerto Rico, the territory of the U.S. Virgin Islands, and eight Tribal
Nations.

the most recent data available at the time of our review. 7 We reviewed
information about these systems, interviewed data users and managers
responsible for these data, and cross-checked data across sources to
ensure consistency. Based on these steps, we determined these data to
be sufficiently reliable for the purposes of describing the status of Public
Assistance funding in Puerto Rico. To identify any challenges FEMA and
Puerto Rico faced implementing the Public Assistance program in Puerto
Rico, we reviewed documentation on the use of alternative procedures for
Public Assistance and interviewed FEMA officials in Puerto Rico, FEMA
Region II, and FEMA headquarters. These interviews focused on the
agency’s responsibilities and processes for ensuring Puerto Rico
implemented the Public Assistance program in accordance with relevant
laws, regulations, policies, and FEMA guidance. Further, we reviewed
documents and interviewed officials from Puerto Rico’s Central Office of
Recovery, Reconstruction, and Resilience (central recovery office).
To examine the extent to which Public Assistance cost estimating

guidance addresses specific conditions in Puerto Rico, we interviewed
FEMA officials in Puerto Rico and at FEMA headquarters. We also
reviewed FEMA documentation on exceptions FEMA developed to adapt
their Cost Estimating Format to specific costs in Puerto Rico. To
determine how well FEMA cost estimating guidance for Public Assistance
alternative procedures aligns with best practices for cost estimating, we
evaluated FEMA’s Public Assistance Alternative Procedures (Section
428) Guide for Permanent Work FEMA-4339-DR-PR issued in April 2018
and updated in September 2019, and FEMA’s Cost Estimation Format for
Large Projects Instructional Guide. We compared FEMA’s guidance for
developing cost estimates outlined in these documents against the best
practices in the 12 steps for cost estimating described in the GAO Cost
Estimating and Assessment Guide which we developed to establish a
consistent methodology that can be used across the federal government
7
These data do not include obligations and expenditures for, among other federal disaster
assistance programs, direct federal mission assignments, in which a federal agency is
tasked with providing eligible emergency work or debris removal services to a territory or
state, or for other categories of mission assignments. An obligation is a definite
commitment that creates a legal liability of the government for the payment of goods and
services ordered or received. For the purposes of this report, obligations represent the
amount of grant funding FEMA provided through the Public Assistance program for
specific projects in Puerto Rico. An expenditure is an amount paid by federal agencies, by
cash or cash equivalent, during the fiscal year to liquidate government obligations. For the
purposes of this report, an expenditure represents the actual spending by the Puerto Rico
government of money obligated by the federal government.

to develop, manage, and evaluate cost estimates. 8 We used a five point
scale for our assessment:
• Fully met. FEMA provided complete evidence that satisfies all the
elements of the step.
• Substantially met. FEMA provided evidence that satisfies a large
portion of the elements of the step.
• Partially met. FEMA provided evidence that satisfies about half of the
• Minimally met. FEMA provided evidence that satisfies a small portion
of the elements of the step.
• Not met. FEMA provided no evidence that satisfies any of the
We have summarized our findings for each of the Cost Guide’s 12 steps
in appendix IV of this report.
To assess the extent to which FEMA has developed policies and

guidance for the Public Assistance program in Puerto Rico and any
challenges recovery partners have had with those policies and guidance,
we reviewed FEMA policy and guidance on national and Puerto Rico-
specific Public Assistance and alternative procedures guidance and
compared them to FEMA’s National Disaster Recovery Framework. 9 We
interviewed officials from FEMA, the central recovery office and six Puerto
Rico government agencies and public corporations headquartered in San
Juan, Puerto Rico. We selected the six entities with the greatest shares of
Public Assistance obligations in Puerto Rico as of December 6, 2018. We
also interviewed Puerto Rico government officials from 10 selected
8
GAO, GAO Cost Estimating and Assessment Guide Best Practices for Developing and
Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March, 2009).The 12-
step process addresses best practices, including defining the program’s purpose,
developing the estimating plan, defining the program’s characteristics, determining the
estimating approach, identifying ground rules and assumptions, obtaining data, developing
the point estimate, conducting sensitivity analysis, performing a risk or uncertainty
analysis, documenting the estimate, presenting it to management for approval, and
updating it to reflect actual costs and changes. Following these steps ensures that realistic
cost estimates are developed and presented to management, enabling them to make
informed decisions.
9
FEMA; National Disaster Recovery Framework, Second Edition (Washington, D.C.: June,
2019).

municipal governments throughout Puerto Rico. 10 We selected these
municipalities based on population and Public Assistance per capita
spending. In interviews with agencies and municipalities, we asked
officials about their experience working with FEMA to implement the
Public Assistance program and any challenges they faced. The results
from our interviews cannot be generalized to all of Puerto Rico’s
government agencies, public corporations, and municipalities; however,
they provide important context about the Public Assistance program in
Puerto Rico.
To describe the structures FEMA and Puerto Rico have created to

manage and oversee Public Assistance program funding, we reviewed
FEMA documentation. This included the Public Assistance Program
Management and Grant Closeout Standard Operating Procedure and
Puerto Rico’s administrative plans and recovery management guide
outlining the territory’s programmatic management and project oversight
activities for these programs, among other relevant documents. Further,
we interviewed FEMA officials and Puerto Rico officials from Puerto
Rico’s central recovery office and reviewed Puerto Rico government
documents related to recovery planning and internal controls.
We conducted this performance audit from March 2018 through January

2020 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
On September 6, 2017, the eye of Hurricane Irma traveled about 50

Background nautical miles to the north of the northern shore of Puerto Rico as a
10
In September 2018, we conducted semi-structured interviews with Puerto Rico’s six
most populous municipalities and the four municipalities with the highest level of Public
Assistance spending per capita in each of FEMA’s four administrative branches in Puerto
Rico. According to 2017 Census estimates, the six most populous municipalities are, in
order of population: San Juan, Bayamón, Carolina, Ponce, Caguas, and Guaynabo.
According to FEMA, the four municipalities with the highest level of Public Assistance
spending per capita per FEMA branch as of August 6, 2018 are: Maricao (Branch I),
Naranjito (Branch II), Maunabo (Branch III), and Guayanilla (Branch IV). Prior to our
September 2018 site visit, we met with officials from the municipalities of Canóvanas,
Cayey, Orocovis, and Toa Baja in August 2018, to gather preliminary information and to
develop the semi-structured interviews.

category 5 hurricane. Less than two weeks later, Hurricane Maria made
landfall as a category 4 hurricane on the main island of Puerto Rico on
the morning of September 20, 2017, with wind speeds up to 155 miles per
hour. The center of the hurricane moved through southeastern Puerto
Rico to the northwest part of the island, as shown in figure 1 below.
Figure 1: The Paths of Hurricanes Irma and Maria
In response to the request of the governor of Puerto Rico, the president

declared a major disaster the day after each hurricane impacted Puerto

Rico. 11 Major disaster declarations can trigger a variety of federal
response and recovery programs, including assistance through FEMA’s
Public Assistance program. 12 Under the National Response Framework,
DHS is the federal department with primary responsibility for coordinating
disaster response, and within DHS, FEMA has lead responsibility. 13
FEMA’s Public Assistance FEMA’s Public Assistance program provides grant funding to state,
Program territorial, local, and tribal governments, as well as certain types of private
nonprofit organizations, to assist them in responding to and recovering
from major disasters or emergencies. 14 As shown in figure 2, Public
Assistance program funds are categorized broadly as either “emergency
work” or “permanent work.” Within those two broad categories are
separate sub-categories. In addition to the emergency work and
permanent work categories, FEMA’s Public Assistance program includes
Category Z, which represents any indirect costs, any direct administrative
costs, and any other administrative expense associated with a specific
project. 15
11
In accordance with the Robert T. Stafford Disaster Relief and Emergency Assistance Act
(Stafford Act), as amended, the President of the United States may declare that a major
disaster or emergency exists in response to a Governor’s or tribal chief executive’s
request if the disaster is of such severity and magnitude that effective response is beyond
the capabilities of a state, tribe, or local government and federal assistance is necessary.
See 42 U.S.C. § 5170.
12
Presidential Policy Directive-8: National Preparedness establishes a national
preparedness system made of an integrated set of guidance, programs, and processes
designed to strengthen the security and resilience of the United States through systematic
preparation for the natural and human-caused threats that pose the greatest risk. This
system breaks preparedness activities into five different lines of effort—prevention,
protection, mitigation, response, and recovery—each of which requires a separate
planning framework.
13
FEMA; National Response Framework, Fourth Edition (October 29, 2019).
14
The Public Assistance program represents the largest share of the Disaster Relief Fund
(DRF), which is the primary source of federal disaster assistance for state and local
governments when a disaster is declared. The DRF is appropriated no-year funding,
which allows FEMA to fund, direct, coordinate, and manage response and recovery
efforts—including certain efforts by other federal agencies and state and local
governments, among others—associated with domestic disasters and emergencies.
15
The Disaster Recovery Reform Act of 2018 amended the definition of management cost,
referred to as category Z. See Pub. L. No. 115-254, § 1215, 132 Stat. 3186, 3449
(codified at 42 U.S.C. § 5165b(a)).

Figure 2: Federal Emergency Management Agency (FEMA’s) Public Assistance Program Categories of Work
a
The Disaster Recovery Reform Act of 2018 amends the definition of Category Z management costs.
See Pub. L. No. 115-254, § 1215, 132 Stat. 3186, 3449 (codified at 42 U.S.C. § 5165b(a)).
Entities Involved in Puerto Given the immense scale and scope of devastation, disaster recovery in
Rico’s Recovery Puerto Rico is a complex and dynamic process involving a large number
of entities. As shown in figure 3, implementing the Public Assistance
program involves recovery partners from the federal government; the
Commonwealth of Puerto Rico; and Puerto Rico government agencies,
public corporations, municipalities, and eligible nonprofits in Puerto Rico.
These recovery partners play a role in implementing the Public
Assistance program by developing projects and providing or receiving
grants and sub-grants (subawards).

Figure 3: Entities Involved in Implementing Federal Emergency Management
Agency (FEMA’s) Public Assistance Program in Puerto Rico
a
Other local eligible entities include eligible private nonprofit organizations that provide eligible
services such as education, utility, emergency or medical, among others.
FEMA. FEMA administers the Public Assistance program in partnership

with Puerto Rico and makes Public Assistance grant funding available to
Puerto Rico.
Puerto Rico Central Office of Recovery, Reconstruction and

Resilience. Puerto Rico was required, as a condition to receiving Public
Assistance grant funding, to establish an oversight authority supported by
third-party experts and provide centralized oversight over recovery funds.
In October 2017, the governor of Puerto Rico established the Central
Office of Recovery, Reconstruction, and Resilience (central recovery
office) to be the recipient for all Public Assistance funding consistent with
the conditions provided in Amendment 5 to the President’s disaster
declaration. 16 The central recovery office is a non-federal entity that
provides a subaward to an applicant to carry out part of the federal
program. As a recipient of federal funds, the central recovery office must
16
Puerto Rico; Amendment No. 5 to Notice of a Major Disaster Declaration, 82 Fed. Reg.
53,514 (Nov. 16, 2017).

oversee subrecipients to ensure that they are aware of and comply with
federal regulations. 17 According to central recovery office officials, the
office was also established to ensure coordination with FEMA across the
numerous partners in recovery.
Commonwealth agencies, local entities, and private non-profits.

Puerto Rico’s agencies, such as the Department of Housing, and public
corporations, such as the Puerto Rico Electric Power Authority, act as
subrecipients. Specifically, they work with FEMA and the central recovery
office to identify, develop, and implement Public Assistance projects.
Local entities, including Puerto Rico’s 78 municipalities and eligible
private non-profits that provide critical services, are also subrecipients of
FEMA Public Assistance funding. As subrecipients, these entities receive
subawards from the central recovery office to carry out work under the
Public Assistance program.
Alternative Procedures for According to a November 2017 amendment to Puerto Rico’s major
Public Assistance Funds disaster declaration, FEMA must obligate all large project funding for
Public Assistance permanent work through alternative procedures due to
the extraordinary level of infrastructure damage caused by Hurricane
Maria, as well as Puerto Rico’s difficult financial position. 18
To develop projects under the Public Assistance program, FEMA and

Puerto Rico officials are to collaborate to identify and document the
damage caused by a disaster to a particular facility. 19 These officials are
to then use the damage description to formulate the scope of work—or
activities required to fix the identified damage—as well as the estimated
cost of these activities.
Under the standard Public Assistance program, FEMA will fund the actual
cost of a large project, and will increase or reduce the amount of funding
based on the cost of completed eligible work. In contrast, in Puerto Rico,
17
Federal regulations adopted by DHS that govern federal grant awards require that
recipients of federal grant awards, including states and territories, must monitor
subrecipients to ensure they are aware of, and comply with, federal regulations. See 2
C.F.R. § 200.331.
18
See 82 Fed. Reg. 53,514.
19
Facility means any publicly or privately owned building, works, system, or equipment,
built of manufactured, or an improved and maintained natural feature. 44 C.F.R. §
206.201(c).

the alternative procedures require that the central recovery office and
subrecipients work collaboratively with FEMA to develop a fixed cost
estimate. According to FEMA officials, once this fixed cost estimate is
agreed to and obligated, subrecipients have flexibility within that fixed
cost estimate to rebuild in the manner that they find most appropriate.
Subrecipients could do the actual work used to develop the fixed cost
estimate, or they could put funds towards another FEMA approved
project. Unlike the standard Public Assistance program, the subrecipient
is responsible for actual costs that exceed the fixed cost estimate. If
actual costs are less than the fixed cost estimate, the subrecipient may
use all or part of excess funds for other eligible purposes, such as for
additional cost-effective hazard mitigation measures to increase the
resiliency of public infrastructure, as detailed in figure 4 below.
Figure 4: Standard Public Assistance and Alternative Procedures for the Federal Emergency Management Agency’s (FEMA)
Public Assistance in Puerto Rico

a
Permanent work projects with an estimated cost of under $123,100 (the threshold for large projects)
are administered using the standard Public Assistance program in Puerto Rico.
b
Examples of eligible purposes include additional cost-effective hazard mitigation measures to
increase the resiliency of public infrastructure, or funding for activities that improve the recipient’s or
subrecipient’s future Public Assistance operations or planning.
The Bipartisan Budget Act Section 20601 of the Bipartisan Budget Act of 2018 authorized FEMA,
of 2018 when using the alternative procedures, to provide assistance to fund the
replacement or restoration of disaster-damaged infrastructure that
provides critical services—such as medical and educational facilities—to
an industry standard without regard to pre-disaster condition. 20 It also
allows for restoration of components not damaged by the disaster when
necessary to fully effectuate restoration of the disaster-damaged
components to restore the function of the facility or system to industry
standards. For example, through the Act, FEMA may fund the restoration
of a disaster-damaged school building—which provides a critical
service—to accepted industry standards applicable to the construction of
education facilities. Therefore, according to FEMA policy, if the school
building was not up to industry standards, or in poor condition prior to the
2017 hurricanes, the Act allows FEMA to fund the restoration of this
building to a better condition than it was in prior to the storms. Further, the
Additional Supplemental Appropriations for Disaster Relief Act of 2019
(Supplemental Relief Act), which was signed into law on June 6, 2019,
provides additional direction to FEMA in the implementation of section
20601. 21 Following the Supplemental Relief Act, FEMA issued additional
20
See Pub. L. No. 115-123, § 20601(1), 132 Stat. 64 (2018). For the purposes of our
report, discussion of the Bipartisan Budget Act of 2018 refers specifically to section 20601.
Critical services include public infrastructure in the following sectors: power, water, sewer,
wastewater treatment, communications, education, and emergency medical care. See 42
U.S.C. § 5172(a)(3)(B). Section 20601 applies only to assistance provided through the
Public Assistance alternative procedures program for the duration of the recovery for the
major disasters declared in Puerto Rico and the U.S. Virgin Islands following hurricanes
Irma and Maria. Further, the Additional Supplemental Appropriations for Disaster Relief
Act of 2019, which was signed into law on June 6, 2019, provides additional direction to
FEMA in the implementation of section 20601. Pub. L. No. 116-20, tit. VI, § 601, 133 Stat.
871, 882 (2019 ). Specifically it directs FEMA to “include the costs associated with
addressing pre-disaster condition, undamaged components, codes and standards, and
industry standards in the cost of repair” when calculating the whether a facility should be
repaired or replaced.
21
We reported in June 2019 that FEMA and Puerto Rico officials have reported challenges
with the implementation of the flexibilities authorized by section 20601 of the Bipartisan
Budget Act. Officials from Puerto Rico’s central government stated that they disagreed
with FEMA’s interpretation of the types of damages covered by section 20601 of the
Bipartisan Budget Act of 2018. In response, FEMA officials in Puerto Rico stated they held
several briefings with the central recovery office to explain FEMA’s interpretation of the
section. GAO-19-594T.

guidance in September 2019 that includes information on eligibility and
applicable industry standards.
FEMA Obligated
Nearly $6 Billion for
Public Assistance in
Puerto Rico as of
September 2019, but
FEMA and Puerto
Rico Face Significant
Challenges in
Developing Projects
Status of FEMA Public Since the 2017 hurricanes, FEMA has obligated nearly $6 billion in Public
Assistance Funding in Assistance program funding for 1,558 projects across Puerto Rico,
according to our analysis of FEMA’s data as of September 30, 2019 (see
Puerto Rico fig. 5). 22 Specifically, FEMA had obligated approximately $5.1 billion for
emergency work projects (categories A and B), $487 million for
permanent work projects (categories C through G), and $315 million for
management costs (Category Z).
22
These data include Public Assistance program grant funding and do not include
obligations and expenditures for, among other things, direct federal mission assignments,
in which a federal agency is tasked with providing eligible emergency work or debris
removal services to a territory or state, or for other categories of mission assignments. For
example, these data do not include obligations for direct federal assistance through
mission assignments for temporary emergency power and grid restoration efforts in Puerto
Rico.

Figure 5: Federal Emergency Management Agency (FEMA) Public Assistance Obligations in Puerto Rico as of September 30,
2019
Note: Numbers might not total 100 percent due to rounding. Emergency protective measures include
activities to lessen the immediate threat to life, public health, or safety such as search and rescue
operations and providing medical care and transport. On October 5, 2019, the Disaster Recovery
Reform Act of 2018 amended the definition of management costs to include any indirect cost, any
direct administrative cost, and any other administrative expense associated with a specific project.
See Pub. L. No. 115-254, § 1215, 132 Stat. 3186, 3449 (codified at 42 U.S.C. § 5165b(a)). Recipients
and subrecipients for disasters or emergencies declared from Aug. 1, 2017 through Oct. 4, 2018 were
able to opt to use FEMA’s interim policy implementing the amended definition or to use previous
existing options, which reimburse management (indirect) costs and direct administrative costs
separately. Puerto Rico as a recipient opted to use the new interim policy, whereas several
subrecipients opted to use previous options, such that the total obligations for Category Z include
both management and direct administrative costs.
Of the nearly $6 billion FEMA has obligated, Puerto Rico has expended
approximately $3.9 billion as of September 30, 2019—about 65 percent of
total Public Assistance program obligations to Puerto Rico—to reimburse
subrecipients for completed work. As shown in table 1, Puerto Rico has

expended about $3.7 billion for emergency work projects, $39 million for
permanent work projects, and $104 million for management costs.
Table 1: Federal Emergency Management Agency’s (FEMA) Public Assistance Obligations to Puerto Rico and Expenditures
for Hurricanes Irma and Maria by Category of Work as of September 30, 2019
Obligated amount Expended amount Percent

Public Assistance work category (in millions) (in millions) expended
Emergency work 5,128.12 3,712.51 72
A - Debris Removal 637.02 427.09 67
B - Protective Measures 4,491.10 3,285.42 73
Permanent work 487.34 38.63 8
C - Roads and Bridges 140.52 32.80 23
D - Water Control Facilities 0.44 0.15 34
E - Public Buildings 43.46 4.00 9
F - Public Utilities 282.03 1.07 <1
G - Recreational or Other 20.89 0.62 3
State management (Category Z) 314.65 104.05 33
Total 5,930.11 3,855.19 65
Source: GAO analysis of data from FEMA’s Emergency Management Mission Integrated Environment and Integrated Financial Management Information System | GAO-20-221
The majority of FEMA’s obligations and the funding Puerto Rico

expended as of September 30, 2019, are for emergency work because
these projects began soon after the disasters struck and focused on
debris removal and providing assistance to address immediate threats to
life and property. In contrast, permanent work projects take time to
identify, develop, and ultimately complete as they represent the longer-
term repair and restoration of public infrastructure, such as a sports
center in Caguas, Puerto Rico, as shown in figure 6 below.

Figure 6: Damaged Sports Complex in Caguas, Puerto Rico
FEMA and Puerto Rico FEMA and Puerto Rico officials identified challenges in developing Public
Face Significant Assistance projects in Puerto Rico. Specifically, they cited: (1) delays in
establishing a cost estimating guidance for projects in Puerto Rico, (2) the
Challenges in Developing
large number of damaged sites that require finalized fixed cost estimates,
Public Assistance Projects and (3) challenges with the implementation of the flexibilities authorized
by section 20601 of the Bipartisan Budget Act.
Delays in establishing cost estimating guidance. Given the

importance of reaching mutual agreement on fixed cost estimates for
alternative procedures projects, FEMA and Puerto Rico have taken a
deliberative approach to establishing the data and procedures that will be
used to develop these fixed cost estimates. This includes, among other
things, adapting the way FEMA estimates costs to the specific post-
disaster economic conditions in the territory, including developing
exceptions to FEMA’s cost estimating guidance. According to FEMA,
these exceptions were developed to account for risk, including higher
anticipated costs due to increased demand for labor, equipment, and
materials in Puerto Rico’s post-disaster economy. To develop these

exceptions, FEMA and the central recovery office established a Center of
Excellence staffed with mutually agreed upon representatives. FEMA
used cost estimators from RAND Corporation (RAND) as their chosen
representatives, while the central recovery office hired separate
contractors as their representatives. According to FEMA officials, the
Center of Excellence was established, among other things, to involve
Puerto Rico in developing cost estimating guidance and to ensure that the
exceptions made to FEMA’s Cost Estimating Format were agreeable to
both parties. However, this approach has been beset by delays. For
example, it took nearly one year for Puerto Rico to hire its chosen
representatives to the Center of Excellence. According to FEMA, the
central recovery office did not select members for the Center of
Excellence until February 2019, which delayed progress on the
development of finalized fixed cost estimates for permanent work. In July
2019, FEMA leadership signed an agreement establishing the exceptions
to FEMA’s cost estimating guidance based on an assessment conducted
by a panel of FEMA engineers. These exceptions are intended to address
certain costs specific to post-disaster conditions in Puerto Rico, for
example adjustments to account for increased labor and material costs.
Large number of damaged sites requiring a fixed cost estimate. In

addition, FEMA and Puerto Rico officials have cited the large number of
sites requiring damage assessments, project development, and mutually
agreed-upon fixed cost estimates as a challenge. As of September 30,
2019, FEMA identified a total of 9,344 damaged sites in various stages of
development. According to FEMA, 6,304 sites (67.5 percent of total sites
identified) have completed damage assessments; 3,021 sites (32.3
percent of total sites identified) are pending the completion of damage
assessments to begin project development; and 19 projects (0.2 percent
of total sites identified) have finalized fixed cost estimates. 23
According to FEMA guidance, October 11, 2019, was the deadline for
completing fixed cost estimates for Public Assistance alternative
procedures projects. 24 However, on October 8, 2019, officials from the
central recovery office requested an extension to the deadline, which
23
As of September 30, 2019, Puerto Rico expended funding on 14 of the 19 obligated
projects with finalized fixed cost estimates. FEMA officials stated that the final number of
projects and fixed cost estimates is subject to change and will depend on how
subrecipients choose to group projects under alternative procedures.
24
FEMA, Public Assistance Alternative Procedures (Section 428) Guide for Permanent
Work FEMA-4339-DR-PR (April 2018 and September 2019).

FEMA granted. FEMA officials acknowledged that significant work
remains on the part of Puerto Rico, subrecipients, and FEMA towards
developing fixed cost estimates for all Public Assistance alternative
procedures projects in Puerto Rico. According to FEMA officials, as of
October 2019, FEMA and Puerto Rico are working together to establish
specific time frames for the completion of fixed cost estimates.
Implementation challenges with Section 20601 of the Bipartisan

Budget Act of 2018. Puerto Rican government and FEMA officials
identified challenges with the implementation of the flexibilities authorized
by section 20601 of the Bipartisan Budget Act. As previously discussed,
this section of the Act allows for the provision of assistance under the
Public Assistance alternative procedures to restore disaster-damaged
facilities or systems that provide critical services—such as medical and
educational facilities to an industry standard without regard to pre-disaster
condition. 25 Officials from Puerto Rico’s central government stated that
they disagreed with FEMA’s interpretation of the types of damages
covered by section 20601 of the Bipartisan Budget Act of 2018. In
response, FEMA officials in Puerto Rico stated they held several briefings
with Puerto Rico’s central recovery office to explain FEMA’s interpretation
of the section, and released new guidance in September of 2019. 26 It is
too soon to assess the impact this guidance may have on current and
future projects, but we will continue to examine this in future work.
We will continue to monitor the status of FEMA’s cost estimating process,

the development of the remaining fixed cost estimates for permanent
25
The Bipartisan Budget Act of 2018 authorized FEMA, when using the Public Assistance
alternative procedures, to provide assistance to fund the replacement or restoration of
disaster-damaged infrastructure that provide critical services to industry standards without
regard to pre-disaster condition. Pub. L. No. 115-123, § 20601(1), 132 Stat. 64 (2018).
Critical services include public infrastructure in the following sectors: power, water, sewer,
wastewater treatment, communications, education, and emergency medical care. See 42
U.S.C. § 5172(a)(3)(B). Section 20601 applies only to assistance provided through the
Public Assistance alternative procedures program for the duration of the recovery for the
major disasters declared in Puerto Rico and the US Virgin Islands following hurricanes
Irma and Maria. Further, the Additional Supplemental Appropriations for Disaster Relief
Act of 2019, which was signed into law on June 6, 2019, provides additional direction to
FEMA in the implementation of section 20601. Pub. L. No. 116-20, tit. VI, § 601, 133 Stat.
871, 882 (2019). For the purposes of our report, discussion of the Bipartisan Budget Act of
2018 refers specifically to section 20601.
26
FEMA, Implementing Section 20601 of the 2018 Bipartisan Budget Act through the
Public Assistance Program., FEMA Recovery Policy FP-104-009-5 Version 2. (September
2019)

work and the impact of FEMA’s new guidance on the implementation of
section 20601 of the Bipartisan Budget Act.
FEMA Has Adapted

Cost Estimating
Guidance to Specific
Conditions in Puerto
Rico, but Could Take
Further Action to Fully
Align the Guidance
with Best Practices
FEMA Has Adapted Its As Puerto Rico is responsible for any costs that exceed fixed cost
Guidance to Estimate estimates for large infrastructure projects under the alternative
procedures, FEMA has adapted its guidance for estimating costs to
Public Assistance Costs to
ensure that these estimates accurately reflect the total costs of Public
Address Post-Disaster Assistance projects. As previously mentioned, FEMA and Puerto Rico
Conditions in Puerto Rico established a Center of Excellence to develop proposed exceptions to
adapt FEMA’s Cost Estimating Format—the agency’s standard guidance
used for Public Assistance cost estimating nationwide—to more
accurately estimate costs in Puerto Rico. After consideration of these
proposals, FEMA approved two exceptions: (1) a cost factor to account
for local labor, equipment, and material costs in Puerto Rico, and (2) a
future price factor and price curve to account for anticipated rises in
construction costs over time due to the massive influx of disaster recovery
funds, coupled with limited material and labor resources in Puerto Rico.
• Cost Factor: According to FEMA officials, during the development of

a cost factor by the Center of Excellence, FEMA learned that Gordian,
a company that provides local cost indices called RSMeans which
FEMA uses as part of their standard Cost Estimating Format, was
developing four localized cost indices to apply to San Juan, urban
areas, rural areas, and remote island (the islands of Vieques and
Culebra) areas of Puerto Rico. FEMA officials told us that these cost
indices compile location-specific construction costs for each of the
four areas. In 2019, a panel of FEMA engineers assessed the
methodologies proposed by RAND, the Center of Excellence, and the
RSMeans localized indices for Puerto Rico. On July 12, 2019, in

agreement with the panel’s assessment, FEMA decided to use
RSMeans’s localized cost indices to act as the cost factor for fixed
cost estimates in Puerto Rico beginning on September 27, 2019. For
fixed cost estimates developed before this date, FEMA used a
different cost index that RSMeans had previously developed for San
Juan. According to FEMA, cost estimates signed before September
27, 2019 using RSMeans’s San Juan cost index as the cost factor are
considered final.
• Future Price Factor and Curve: According to FEMA officials, FEMA
began using a future price factor—an economic model based on
expected construction conditions to estimate construction costs
across ten years—in July 2019 to estimate costs in Puerto Rico.
FEMA is using this future price factor along with the cost factor. FEMA
has also asked RAND to develop a future price curve, an analysis that
will adjust as time goes on to account for changing economic
conditions, to eventually replace the future price factor. FEMA
estimates that RAND will take until November 2019 to develop the
future price curve, and that the future price factor is being used in the
meantime. FEMA officials stated that cost estimates produced using
the future price factor are considered final and will not be eligible for
revisions in the future once FEMA implements the future price curve.
According to FEMA officials, the use of the cost factor combined with the
future price factor and curve are intended to adapt FEMA’s cost
estimating guidance to the specific post-disaster economic conditions in
Puerto Rico.
FEMA Cost Estimating FEMA’s cost estimating guidance for Public Assistance fully or
Guidance Met Most Cost substantially met nine of the 12 steps from GAO’s Cost Estimating and
Assessment Guide (GAO Cost Guide). 27 However, the guidance partially
Estimating Best Practices,
met two and minimally met one of the remaining cost estimating steps, as
but FEMA Could Take shown in figure 7 below. The GAO Cost Guide outlines best practices for
Further Action to Fully cost estimating and presents 12 steps that, when incorporated into an
Align with Best Practices agency’s cost estimating guidance, should result in reliable and valid cost
estimates that management can use to make informed decisions. 28 A
reliable cost estimate is critical to the success of any construction
27
FEMA, Cost Estimating Format for Large Projects Instructional Guide V2.1, (September,
2009); FEMA. Public Assistance Alternative Procedures (Section 428) Guide for
Permanent Work FEMA-4339-DR-P, (September, 2019)
28
GAO-09-3SP.

program. Such an estimate provides the basis for informed decision
making, realistic budget formulation and program resourcing, and
accountability for results. For example, FEMA, Puerto Rico and
subrecipients rely on cost estimates to help ensure that funding is
sufficient for the costs of the Public Assistance projects carried out under
the fixed cost estimate. Accurate and reliable cost estimating is especially
important in Puerto Rico where all large permanent Public Assistance
projects are being developed under the alternative procedures, which
require a fixed cost estimate that cannot be revised once the award is
made. Given Puerto Rico’s financial situation, accurate cost estimates are
necessary so that Puerto Rico has adequate funds to complete Public
Assistance projects.
Figure 7: GAO Assessment of Federal Emergency Management Agency (FEMA)

Cost Estimating Guidance for Public Assistance Projects Compared to the 12 Steps
for Developing a Reliable and Valid Cost Estimate
Note: Our assessments of FEMA’s cost estimating guidance in comparison with the 12 steps
identified in GAO Cost Estimating and Assessment Guide fall in the following categories:
Fully met: FEMA provided complete evidence that satisfies the elements of the step;
Substantially met: FEMA provided evidence that satisfies a large portion of the elements of the step;
Partially met: FEMA provided evidence that satisfies about half of the elements of the step;
Minimally met: FEMA provided evidence that satisfies a small portion of the elements of the step; and
Not met: FEMA provided no evidence that satisfies any of the elements of the step.

For example, on the basis of our analysis, we determined that FEMA’s
guidance fully met the step to “define the estimate’s purpose” because it
describes the estimate’s purpose, level of detail required, and overall
scope. In addition, the guidance provides a time frame for which the
estimates must be developed and reach agreement. FEMA’s guidance
substantially met another step, “identify the ground rules and
assumptions”, because it provides measures to ensure assumptions are
not arbitrary, are founded on expert judgments, and are documented.
However, we rated this step as substantially met instead of fully met
because FEMA’s guidance does not address all of GAO’s best practices
for ground rules and assumptions. For example, it does not discuss the
risk of an assumption being incorrect and the resultant effect on the cost
estimate. Additionally, FEMA guidance substantially met the step to
“document the estimate” because it contains, among other things, basic
information about the project and the estimate; a description of the scope
of work; the basis for the estimate; and supporting backup information.
However, we assessed this step as substantially met instead of fully met
because FEMA policy does not require documentation to include a
discussion of high risk areas.
Further, we found that FEMA’s guidance for cost estimating does not fully
or substantially meet three steps: (1) conduct a sensitivity analysis; (2)
obtain the data; and (3) conduct a risk and uncertainty analysis. 29
Sensitivity analysis (Minimally met): We found that FEMA’s cost

estimating guidance only minimally met the best practice regarding
sensitivity analysis. A sensitivity analysis addresses some of the
uncertainty in a cost estimate by testing assumptions and other factors
that could change cost. By examining each assumption or factor
independently, while holding all others constant, the cost estimator can
evaluate the results to discover which assumptions or factors most
influence the estimate. A sensitivity analysis also requires estimating the
high and low uncertainty ranges for significant cost driver input factors.
According to the GAO Cost Guide, when an agency does not identify the
effect of uncertainties associated with different assumptions, this
increases the chance that decisions will be made without a clear
understanding of these impacts on costs.
29
For a summary of our assessment for each of GAO’s 12 steps, see appendix II.

According to FEMA officials, FEMA’s cost estimating guidance accounts
for construction, cost, and market risks over time which allows FEMA to
plan and estimate costs for unknown or unforeseen circumstances such
as cost escalation or overhead. In addition, FEMA officials stated that
their use of RSMeans unit costs, a benchmark industry standard based
on ongoing iterative analysis of construction costs nationwide, allows
FEMA to account for fluctuations and uncertainties in the market.
However, we rated this step as minimally met because FEMA guidance
does not indicate that cost estimators are to conduct a sensitivity analysis
as part of FEMA’s cost estimating process. Specifically, the guidance
does not require that an estimator examine the effect of changing
assumptions and the effect these changes could have on a cost estimate.
Since the guidance does not direct estimators to conduct a sensitivity
analysis, estimators may not fully understand which variable most affects
the cost estimate and FEMA risks making decisions without a clear
understanding of the impact of costs.
Obtaining the data (Partially met): We found that FEMA’s cost

estimating guidance only partially met the best practice for obtaining
data—assembling information to serve as the foundation of a cost
estimate. The quality of the data obtained affects a cost estimate’s overall
credibility. Depending on the data quality, an estimate can range from a
mere guess to a highly defensive cost position. We found that FEMA did
not meet some of the best practices for obtaining data. Specifically,
FEMA’s guidance did not outline procedures for making sure data was
validated using historical data as a benchmark for reasonableness. In
addition, FEMA’s guidance did not stipulate that data be normalized to
remove the effects of inflation or analyzed with a scatter plot to determine
trends and outliers. As mentioned previously, FEMA used a city cost
index based on San Juan as an interim measure to estimate costs
throughout Puerto Rico until September, 2019 when FEMA began using
additional cost indices to target costs in particular regions of Puerto Rico.
Similarly, FEMA has been using a static future price factor as an interim
measure until a more dynamic and iterative future price curve is finalized.
FEMA does not plan to adjust cost estimates developed using these
interim measures. Without adjusting these costs when better data
becomes available consistent with the obtaining the data step, FEMA
risks creating estimates that may not be based on accurate data.
According to FEMA, estimates are developed based on historical costs or

nationally available industry standard data. In addition, FEMA officials
stated that FEMA does not revisit cost estimates to reflect updated
market conditions or newly available cost information because FEMA

uses an industry standard cost database that is updated quarterly. FEMA
officials stated that the interim measures used to estimate costs are
intended to enable work to continue and cost estimates to be developed
while the future cost curve is being developed. However, we rated the
step relating to obtaining data as partially met because without finalizing
the future cost curve, and updating estimates to reflect this information,
estimates may not be based on accurate data. Additionally, while the use
of industry standard cost estimating resources addresses some best
practices for this step such as data normalization and data validation,
industry data is only one of many sources referenced in FEMA’s
guidance. For other data sources identified, FEMA guidance does not
describe a process to analyze the data for cost drivers or to adequately
document the data.
Risk and uncertainty analysis (Partially met): We found that FEMA’s

cost estimating guidance does not include best practices consistent with
performing a statistical analysis of risk to determine a range of possible
costs and the level of confidence in achieving the estimate. By conducting
a risk and uncertainty analysis, a cost estimator can model the effect of
schedules slipping and missions changing, allowing for a known range of
potential costs. Having a range of costs around a point estimate is useful
to decision makers because it conveys the level of confidence in
achieving the most likely cost and informs estimators about potential
risks. 30 We found that FEMA’s cost estimating guidance does not require
a statistical analysis of risks to be performed to determine a range of
possible costs. While contingencies are accounted for within the
guidance, they are not derived from a statistical analysis, nor do they
reflect a level of confidence in the estimate.
According to FEMA, risks associated with changing costs and conditions

over the life of a Public Assistance alternative procedures construction
project is not a risk that the federal government takes on. Rather, the risk
is transferred to the recipient and subrecipients responsible for executing
work using Public Assistance alternative procedures funding. In addition,
FEMA officials told us that alternative procedures funding is not always
used to restore facilities to pre-disaster condition, and therefore may not
represent the final cost of work completed. In addition, the procedures are
designed to incentivize subrecipients to manage grants and use excess
funds for eligible work, as described earlier. However, GAO’s Cost Guide
30
GAO-09-3SP.

states that point estimates alone are insufficient for good decision-
making. For management to make good decisions, the program estimate
must reflect the degree of uncertainty, so that a level of confidence can
be given about the estimate regardless of the entity holding the risk. In
the case of alternative procedures projects in Puerto Rico, where actual
costs that exceed the estimate are borne by the recipient or subrecipient,
estimates that accurately reflect the degree of uncertainty are important in
establishing a level of confidence about the estimate.
While FEMA fully or substantially met nine of the 12 steps in the GAO
Cost Guide, FEMA could improve its cost estimating guidance to ensure
that all best practices in the 12 steps in the GAO Cost Guide are fully met.
In doing so, FEMA could further enhance the reliability of its cost
estimating guidance.
FEMA Has
Developed Public
Assistance Program
Policies and
Guidance over Time
for Puerto Rico, but
Recovery Partners
Reported Challenges
FEMA Public Assistance In response to the complexity of the recovery, as well as the nature of
Program Policies and change in a recovery environment, FEMA has developed and issued
guidance that is specific to the implementation of the Public Assistance
Guidance for Puerto Rico
program in Puerto Rico. As previously discussed, disaster recovery in
Puerto Rico is a complex and dynamic process that requires the
coordination of many entities, including FEMA, the government of Puerto
Rico, and numerous subrecipients. Recovery in Puerto Rico also involves
the use of Public Assistance structures including alternative procedures
and new flexibilities afforded to FEMA under the Bipartisan Budget Act of
2018.
FEMA officials told us that many elements of the Public Assistance

process in Puerto Rico are the same as in other declared disasters
across the United States. Therefore, according to FEMA officials, the

standard guidance for the Public Assistance program, Public Assistance
Policy and Procedures Guide (Policies and Procedures Guide), generally
applies in Puerto Rico. 31
FEMA has also developed policies and guidance to address the specific
recovery circumstances in Puerto Rico. For example, in April of 2018 and
September of 2019, FEMA published the Public Assistance Alternative
Procedures Guide for Permanent Work to clarify how FEMA would
implement the program in Puerto Rico. 32 This guidance describes the
scope and limitations of the alternative procedures; highlights changes to
aspects of the Public Assistance program to which these procedures
apply; identifies responsibilities for certain activities; and documents
timelines for key actions and decisions. FEMA also issued a policy on the
agency’s implementation of section 20601 of the Bipartisan Budget Act as
it applies in Puerto Rico in September of 2018, detailing the applicability
of the section to specific critical services and outlining eligible industry
standards for purposes of authorized projects, among other things.
Following the Supplemental Relief Act, FEMA issued guidance in
September 2019 that includes additional information on eligibility and
applicable industry standards. According to FEMA officials, FEMA has
also developed and implemented training specific to recovery in Puerto
Rico. This training has included presentations to the central recovery
office and subrecipients on the flexibilities of the Bipartisan Budget Act
and alternative procedures, among other things.
Recovery Partners in FEMA has iteratively developed, refined, and clarified Public Assistance
Puerto Rico Identified guidance in Puerto Rico to respond and adapt to changing recovery
conditions since the 2017 hurricanes. While iterative and responsive
Challenges with the
guidance is necessary in a complex and changing recovery, the pace of
Accessibility of FEMA change necessitates that all involved recovery entities have real-time
Public Assistance Policies accessibility to current applicable FEMA guidance. Officials from the
and Guidance central recovery office and four Puerto Rico government agencies we
spoke with stated that they did not consistently have the guidance they
31
Other guidance applicable to Puerto Rico but not developed specifically for the island’s
recovery include the Public Assistance Alternative Procedures for Direct Administrative
Costs, and Instruction on Implementation of the Environmental Planning and Historic
Preservation Responsibilities and Program Requirements.
32
FEMA. Public Assistance Alternative Procedures (Section 428) Guide for Permanent
Work FEMA-4339-DR-PR (Washington, DC: April 2018 and September 2019).

needed to implement the Public Assistance program. 33 For example, an
official from one Puerto Rico agency said that they delayed starting on
any large Public Assistance projects through alternative procedures
because they were waiting for FEMA to issue additional guidance.
Similarly, we reported in March 2019 that four municipal officials stated
that they were waiting on additional instruction from FEMA to establish
more clear and consistent guidance to begin projects in Puerto Rico. 34
According to FEMA officials, the agency works with Puerto Rico

government officials and subrecipients to provide relevant guidance and
technical assistance throughout the Public Assistance project
development process. However, we found that pertinent guidance may
not be shared with key recovery partners. For example, FEMA officials
told us that the Standard Operating Procedure for Alternative Procedures
(SOP) was available as of March 2019, but remains in draft form as of
October 2019, pending finalized information about cost estimating
procedures. This SOP provides instruction on specific procedures to
implement the Public Assistance alternative procedures guide. In April
2019, FEMA officials described the SOP as a “living document”; they also
stated that the draft SOP is in effect and has been sent to the central
recovery office for further dissemination to subrecipients. While the SOP
document is still in draft, according to FEMA officials, it is operative
guidance that FEMA expects the central recovery office to disseminate to
subrecipients. However, in June 2019, central recovery office personnel
told us they did not view the SOP as being in effect as it was still in draft
form. As such, central recovery office officials stated they had not
distributed the SOP to subrecipients. FEMA officials stated that they rely
on the central recovery office to disseminate at least some FEMA
guidance and policy to subrecipients in Puerto Rico, including
municipalities and government agencies. As the recipient for all Public
Assistance funding in Puerto Rico, the central recovery office is
responsible for monitoring and providing technical assistance to
subrecipients to ensure that federal funding is used in accordance with
33
During interviews with officials from six selected agencies and public corporations and
10 selected municipalities, officials identified various challenges. When we report the
number of agencies, public corporations, or municipalities that identified a particular
challenge, this does not necessarily indicate that the remaining agencies, public
corporations, or municipalities did not also experience the challenge. Rather, it indicates
that those agencies, public corporations, or municipalities did not raise the challenge
during our interviews.
34
GAO-19-256

federal statutes, regulations, and the requirements of the grant. 35 FEMA
officials also stated that subrecipients have an assigned FEMA point of
contact to assist them through the project development process, including
communicating policy information and updates. However, municipal and
Puerto Rico agency officials we spoke to said that confusion persisted in
part due to changing points of contact.
FEMA’s reliance on the central recovery office or individual FEMA staff to

deliver and distribute FEMA guidance poses a risk that the guidance is
not made accessible to all partners involved in recovery, including
subrecipients. While FEMA officials told us that FEMA assigns a point of
contact to subrecipients to provide guidance and other necessary
information throughout the project development process, Puerto Rico
officials described a significant amount of “back and forth” with FEMA
regarding requests for clarification, guidance, or instruction. FEMA
officials acknowledge that FEMA has faced difficulties in disseminating
information in Puerto Rico. According to FEMA officials, FEMA does not
maintain a repository of Public Assistance policies and guidance available
to all relevant recovery partners. The accessibility of FEMA guidance is
especially important because FEMA releases iterative guidance to
respond and adapt to changing recovery circumstances, such as updated
legislation, among other things. Misunderstandings across recovery
partners about guidance applicability raise concerns that subrecipients do
not understand which guidance is currently in effect or how they should
proceed in accordance with FEMA policy. Without real-time access to the
totality of FEMA’s current applicable guidance, recovery partners risk
using guidance that has been revised or replaced.
According to FEMA’s National Disaster Recovery Framework, the federal

government has the role of ensuring that information is distributed in an
accessible manner such that all partners are informed of and aware of the
recovery process. 36 Developing a repository of current applicable policy
and guidance and making it available to all relevant recovery partners in
Puerto Rico, including subrecipients, would improve the accessibility of
the information and provide greater assurance that recovery partners are
aware of current applicable guidance.
35
See generally 44 C.F.R. part 206; 2 C.F.R. § 200.331.
36
FEMA. National Disaster Recovery Framework, Second Edition (Washington, D.C.:
June, 2019).

Puerto Rico and
FEMA Have
Structures in Place to
Manage and Oversee
Public Assistance
Funding and FEMA
Has Instituted
Additional Controls to
Mitigate Risk
Puerto Rico Established Following the 2017 hurricanes, Puerto Rico took several steps to provide
an Office to Manage and management and oversight of the Public Assistance program to ensure
the program is implemented in compliance with applicable laws and
Oversee Public Assistance
regulations, as well as FEMA policies and guidance. Specifically, Puerto
Funding and Help Ensure Rico (1) established a central recovery office to provide management and
Compliance with FEMA oversight of recovery funds; (2) developed an administrative plan, as
Policy required by FEMA policy; (3) developed an internal controls and recovery
management plan; and (4) created a system to oversee and assess
subrecipient risk.
First, in accordance with Amendment 5 to the President’s disaster

declaration, the central recovery office has been supported by third-party
experts to help it establish its structure and carry out its management and
oversight mission. Specifically, the central recovery office has hired
contractors to help perform the following functions:
• Design a management guide and assess subrecipient risk.

According to central recovery office officials, the office hired
contractors to develop management protocols and guidance to ensure
compliance with federal and state law, regulation, and guidance. The
office also tasked these contractors with developing a system to
oversee subrecipients using risk-based oversight.
• Provide technical assistance. Central recovery office officials also
hired contractors to provide technical assistance and advise Puerto
Rico’s government agencies and municipalities regarding recovery
processes. This includes helping subrecipients define the scope of

damages, and providing technical assistance to develop Public
Assistance projects, among other things. The recovery office also
tasked these contractors with overseeing grant accounting and
reviewing reimbursement requests from subrecipients for eligible
Public Assistance work performed.
• Develop data systems to track the central recovery office’s work.
The central recovery office launched an online transparency portal,
with the assistance of contractors, that is intended to provide a
breakdown of FEMA Public Assistance and other federal funding
made available for disaster recovery in Puerto Rico. 37 According to
central recovery office officials, in addition to the development of the
online transparency portal, contractor personnel also developed
systems to track internal recovery data.
Second, to meet FEMA reporting requirements, the central recovery office
developed an administrative plan—or FEMA State Agreement—in 2019
for the Public Assistance program following the 2017 hurricanes. This
plan outlines the central recovery office’s management and oversight
activities as well as the procedures that Puerto Rico must follow in
implementing the programs. Puerto Rico is responsible, as required in the
FEMA State Agreement, to ensure that subrecipients are in compliance
with the conditions of the disaster grant award. For example, the plan
emphasizes FEMA’s requirement that Puerto Rico submit quarterly
progress and financial reports on the status of projects. 38 Further, the plan
describes Puerto Rico’s specific roles and responsibilities for managing
and overseeing the program. For example, according to the Puerto Rico
2019 Public Assistance Administrative Plan, the central recovery office is
responsible for, among other things, processing requests for time
extensions to complete projects and conducting quarterly reviews, site
inspections, and audits to ensure program compliance.
Third, in addition to the administrative plan, in March 2019, the central

recovery office released the Disaster Recovery Federal Funds
Management Guide (management guide) that includes an internal
controls plan and other policies and procedures for managing recovery
37
https://www.recovery.pr/
38
For Public Assistance program projects to comply with the requirements of 2 C.F.R. §
200.331, monitoring and reporting program performance, among other things, grantees
are responsible for managing the day-to-day operations of grant and subgrant supported
activities. Grantees must monitor grant and subgrant supported activities to ensure
compliance with applicable Federal requirements.

funds. The management guide’s 14 chapters outline roles,
responsibilities, policies and procedures on various recovery functions
including procurement, payment and cash management, and subrecipient
management and oversight, among other things. FEMA officials told us
that they reviewed portions of the management guide, including sections
on the central recovery office’s payment and cash management plan and
subrecipient oversight. Further, FEMA worked with the central recovery
office to make revisions to the plan, which included, adding clarifying
information and correcting instances of duplication in the guidance,
among other things.
In addition, the central recovery office, with the help of contractors, is

taking steps to assist subrecipients in meeting compliance requirements
and supplementing their management capacity. FEMA and Puerto Rico
government agency officials cited varying levels of capacity to manage
federal grant funds, including Public Assistance funding. For example,
agency officials at one government agency we spoke with stated that they
were performing their own federal grants management and had prior
experience managing large federal funds. Other Puerto Rico government
officials we interviewed reported that central recovery office contractors
have helped augment capacity to oversee federal funds. For example,
officials from one subrecipient, a Puerto Rico public corporation, said that
their agency did not have prior experience managing federal funds on
such a large scale. The official told us that in order to bolster the capacity
of the agency to oversee these grant funds, central recovery office
contractors work closely with the agency to help them manage Public
Assistance funding. Similarly, officials at one Puerto Rico government
agency stated that the central recovery office offered help on uploading
and validating grant data.
Fourth, as detailed in its management guide, the central recovery office

has also developed criteria to evaluate subrecipients’ risk of
noncompliance with federal laws and regulations, as well as FEMA policy.
According to the procedures outlined in the central recovery office’s
management guide, each subrecipient is to be assessed annually to
determine whether they are at a low, moderate, or high risk for
noncompliance. The central recovery office is to place additional award
conditions on subrecipients with risk factors identified through the risk
assessment process. These may include additional oversight and more
frequent on-site visits from the central recovery office. Additionally, central
recovery office guidance states that corrective actions are to be taken in
cases when deficiencies are found during audits.

FEMA Has Instituted In March 2019, we reported that FEMA instituted a manual
Additional Controls to reimbursement process in November 2017 for subrecipients in Puerto
Rico for federal funds, including Public Assistance funds, to mitigate
Protect the Federal fiduciary risk and decrease the risk of misuse of funds. 39 Specifically,
Investment in Puerto FEMA officials stated that they decided to institute this process because
Rico’s Recovery the government of Puerto Rico had expended funds prior to submitting
complete documentation of work performed. 40 According to FEMA
officials, they also decided to institute the manual reimbursement process
due to Puerto Rico’s financial situation, weaknesses in internal controls,
and the large amount of recovery funds, among other things.
The manual reimbursement process required that FEMA review each

reimbursement request before providing Public Assistance funds to
mitigate risk and help ensure financial accountability. In Puerto Rico, the
manual reimbursement process requires that the central recovery office
fill out the Office of Management and Budget’s Standard Form 270 and
submit supporting documentation to FEMA before obligated funds can be
withdrawn by Puerto Rico through the central recovery office and
reimbursed to subrecipients. 41 Subsequently, FEMA must review the
submitted Standard Form 270 and all project documentation for
completeness, compliance, and accuracy before disbursing funds to the
recipient. In cases where FEMA requires additional documentation to
process a Standard Form 270 request, FEMA will submit requests for
information asking the central recovery office to supply the information
needed for FEMA to complete the review. 42
39
Federal grant award regulations allow FEMA to impose additional grant award
conditions in specific circumstances, such as to mitigate risk and ensure fiscal
accountability of the recipient or subrecipient. See 2 C.F.R. §§ 200.205, 200.207; see
generally 2 C.F.R. part 200. These additional award conditions may include requiring
payments as reimbursements rather than advance payments; withholding authority to
proceed to the next phase until receipt of evidence of acceptable performance within a
given period of performance; requiring additional, more detailed financial reports, among
other conditions.
40
The central recovery office is responsible for collecting and submitting all documentation
requested by FEMA from subrecipients.
41
Standard Form 270: Request for Advance or Reimbursement.
42
Additional documentation requested by FEMA to process a Standard Form 270 request
includes, among other things, copies of contracts, cost of labor estimates, bid documents,
and evidence of payment.

On March 25, 2019, FEMA and the government of Puerto Rico, through
the central recovery office, signed an agreement allowing the central
recovery office to directly access federal grant funds and reimburse
subrecipients for Public Assistance work they perform. During FEMA’s
review of the central recovery office’s management guide, FEMA asked
for revisions to sections, including chapters related to payment and cash
management and subrecipient management and monitoring. According to
the March 2019 agreement, these policies and procedures were
developed in collaboration with FEMA, and comments and concerns
provided by FEMA were addressed. FEMA officials also told us that they
sampled Public Assistance grant documentation for completeness to
ensure that the reimbursement requested was eligible for payment.
According to FEMA officials, FEMA communicated minor discrepancies
with the central recovery office for resolution, but said that they did not
find any significant discrepancies during their completeness review. On
April 1, 2019, FEMA removed the manual reimbursement process and
began a transition to allow the central recovery office to make direct
payments to subrecipients.
In July 2019, FEMA announced that it would reinstate the manual

reimbursement process due to, “ongoing leadership changes within the
Puerto Rican government, combined with continued concern over Puerto
Rico’s history of fiscal irregularities and mismanagement.” 43 FEMA said
that these additional steps are being taken in order to protect the federal
investment in Puerto Rico’s recovery.
We previously reported that FEMA and central recovery office officials

told us that the manual reimbursement process caused delays in
reimbursements, but once FEMA increased the number of personnel
devoted to reimbursement reviews, delays decreased. In September
2019, FEMA once again lifted the manual reimbursement process
following a meeting between FEMA and Governor Vásquez’s senior
leadership. According to FEMA, the agreement to remove the manual
reimbursement process is contingent on Puerto Rico’s continued ability to
implement the mutually-acceptable internal controls plan. FEMA officials
also stated that they are selecting samples from fiscal year 2019 to test
Puerto Rico’s internal controls, and plan to move to a quarterly testing
routine after testing for fiscal year 2019 is complete.
43
FEMA, FEMA to Reinstate Manual Drawdown Process for the Commonwealth of Puerto
Rico (July 25, 2019)

As part of our ongoing review, we will continue to monitor the central
recovery office’s management and oversight of Public Assistance funding,
as well as of FEMA’s oversight of the federal investment in Puerto Rico’s
recovery.
After the devastation of the catastrophic 2017 hurricane season, FEMA

Conclusions and Puerto Rico face a recovery of enormous scope. Puerto Rico
estimates that $132 billion in funding will be needed to repair and
reconstruct the infrastructure damaged by the hurricanes through 2028,
and FEMA has identified nearly ten thousand damaged sites in need of
Public Assistance funding. FEMA has taken steps to adapt its guidance to
estimate costs to post-disaster conditions in Puerto Rico, but
strengthening its cost estimating guidance could help FEMA provide
greater assurance that its cost estimating guidance for Public Assistance
projects is reliable. In addition, given the large number of individuals and
entities involved in Puerto Rico’s complex recovery, ensuring that all
recovery partners have easy access to the most current applicable policy
and guidance could help clarify which FEMA guidance and policies are in
effect.
We are making the following two recommendations to FEMA:

Recommendations for
Executive Action The FEMA administrator should revise FEMA’s cost-estimating guidance
for Public Assistance projects to fully align with all 12 steps in the GAO
Cost Estimating and Assessment Guide. (Recommendation 1)
The FEMA administrator should develop a repository for all current

applicable Public Assistance policies and guidance for Puerto Rico and
make it available to all recovery partners, including subrecipients.
(Recommendation 2)
We provided a draft of this product to FEMA, DHS and Puerto Rico’s

Agency Comments Central Office of Recovery, Reconstruction, and Resilience (central
and Our Evaluation recovery office) for comment. In its comments, reproduced in appendix III,
DHS concurred with our recommendations. FEMA also provided technical
comments, which we incorporated as appropriate.
DHS concurred with our first recommendation that FEMA revise its cost-
estimating guidance for Public Assistance projects to fully align with all 12
steps in the GAO Cost Estimating and Assessment Guide. DHS stated

that FEMA will create a quality assurance checklist as an addendum to
FEMA’s Cost Estimating Format (CEF) to ensure that cost estimates
reflect best practices from the GAO Cost Estimating and Assessment
Guide. This action is a positive step to addressing our recommendation
and we will monitor FEMA’s efforts to complete this work.
In DHS’s concurrence to our second recommendation that FEMA develop

a repository for all current applicable Public Assistance policies and
guidance for Puerto Rico to be made available to all recovery partners,
DHS requested that GAO consider this recommendation resolved and
closed as implemented. DHS stated that FEMA maintains Public
Assistance policy and guidance documents, including those specific to
Puerto Rico, on the agency’s public web site, which FEMA stated it will
continue to update. DHS also stated that FEMA maintains non-publicly
available reference documents on the agency’s internal web site through
the Grants Manager and Grants Portal systems. As we noted in our
report, Puerto Rico’s recovery is a complex and dynamic process that
requires the coordination of many recovery partners, including numerous
municipalities and commonwealth agencies. For this reason, ensuring
that information is distributed in an accessible manner would provide
greater assurance that all recovery partners are aware of the most current
and applicable Public Assistance policies and guidance. We will monitor
FEMA’s public and internal web sites, including policy and guidance
updates, to assess whether the actions outlined by FEMA meet the intent
of our recommendation.
COR3 also provided comments to our draft report, which we reproduced

in appendix IV. In its comments, COR3 stated that it works with Public
Assistance applicants to, among other things, provide technical
assistance and training, and to monitor projects. COR3 also stated that it
has established joint efforts with FEMA to improve COR3’s technical
assistance, as well as compliance and monitoring efforts.
We are sending copies of this report to the appropriate congressional

committees, the Secretary of Homeland Security, the Administrator of
FEMA, the Puerto Rico government, and other interested parties. In
addition, the report is available at no charge on the GAO website at
http://www.gao.gov.

If you and your staff have any questions, please contact me at (404) 679-
1875 or curriec@gao.gov. GAO staff who made key contributions to this
report are listed in appendix V.
Chris P. Currie
Director, Homeland Security and Justice

List of Requesters
The Honorable Michael B. Enzi

Chairman
Committee on the Budget
United States Senate
The Honorable Ron Johnson

Chairman
The Honorable Gary C. Peters
Ranking Member
Committee on Homeland Security and Governmental Affairs
The Honorable Marco Rubio

Chairman
Committee on Small Business and Entrepreneurship
The Honorable Rand Paul, M.D.

Chairman
Subcommittee on Federal Spending Oversight
and Emergency Management
Committee on Homeland Security and Governmental Affairs
The Honorable Maxine Waters

Chairwoman
Committee on Financial Services
House of Representatives
The Honorable Bennie G. Thompson

Chairman
Committee on Homeland Security
The Honorable Carolyn Maloney

Chairwoman
The Honorable Jim Jordan
Ranking Member
Committee on Oversight and Reform

The Honorable Nydia Velázquez
Chairwoman
Committee on Small Business
The Honorable Peter DeFazio

Chairman
The Honorable Sam Graves
Ranking Member
Committee on Transportation and Infrastructure
The Honorable Al Green

Chairman
Subcommittee on Oversight and Investigations
Committee on Financial Services
The Honorable Peter T. King

Ranking Member
Subcommittee on Emergency Preparedness, Response and Recovery
Committee on Homeland Security
The Honorable Emanuel Cleaver, II

The Honorable Michael McCaul

The Honorable Gary Palmer

The Honorable Ann Wagner


Appendix I: The Status of Public Assistance
Program Funding in Puerto Rico
Since September 2017, the Federal Emergency Management Agency

(FEMA) obligated nearly $6 billion in Public Assistance grant funding for
1,558 projects across Puerto Rico as of September 30, 2019. 1
Specifically, FEMA had obligated $5.13 billion for emergency work
projects (categories A and B), about $487 million for permanent work
projects (categories C through G), and $315 million for management
costs, (category Z). 2 As of that date, Puerto Rico expended nearly $3.9
billion—about 65 percent of total Public Assistance obligations to Puerto
Rico—to reimburse subrecipients for completed work. Of this, Puerto Rico
expended about $3.7 billion (96 percent of all expended funds) for
emergency work projects, $38.6 million (1 percent) for permanent work
projects, and $104 million (3 percent) for management costs.
The majority of FEMA’s obligations and the funding Puerto Rico

expended as of September 30, 2019 are for emergency work projects
because these projects began soon after hurricanes Irma and Maria
struck and focused on debris removal and providing assistance to
address immediate threats to life and property. In contrast, permanent
work projects take time to identify, develop, and ultimately complete as
they represent the longer-term repair and restoration of public
infrastructure. While the data in this appendix represent the status of
Public Assistance funding as of September, 2019, the amount of grant
funding FEMA obligates and Puerto Rico expends will likely increase over
time as additional projects are finalized and approved.
Emergency Work. As of September 30, 2019, FEMA obligated a total of

$5.13 billion for approximately 1,200 emergency work projects across
1
The Public Assistance program provides funding for debris removal efforts, life-saving
emergency protective measures, and the repair or replacement of disaster-damaged
publicly-owned facilities, roads and bridges, electrical utilities, and more. An obligation is a
definite commitment that creates a legal liability of the government for the payment of
goods and services ordered or received. For the purposes of this report, obligations
represent the amount of grant funding FEMA provided through the Public Assistance
program for specific projects in Puerto Rico. An expenditure is an amount paid by federal
agencies, by cash or cash equivalent, during the fiscal year to liquidate government
obligations. For the purposes of this report, an expenditure represents the actual spending
by Puerto Rican government of money obligated by the federal government. These data
do not include obligations and expenditures for, among other federal disaster assistance
programs, direct federal mission assignments, in which a federal agency is tasked with
providing eligible emergency work or debris removal services to a territory or state, or for
other categories of mission assignments.
2
Management costs are any indirect cost, any direct administrative cost, and any other
administrative expense associated with a specific project.

Puerto Rico. These projects focus on debris removal activities and

providing assistance to address immediate threats to life and property.
• Category A: Debris Removal. FEMA obligated $637.0 million and

Puerto Rico expended $427.1 million for 331 projects focused on
debris removal activities in Puerto Rico under category A.
• Category B: Emergency Protective Measures. FEMA obligated
nearly $4.5 billion for 871 projects under Category B. Of this, Puerto
Rico has expended $3.29 billion. For example, FEMA has obligated
more than $140 million to the Puerto Rico Aqueducts and Sewer
Authority under category B to fund emergency protective measures,
including using back-up generators to supply water to the island after
Hurricane Maria, among other things.
Permanent Work. As of September 30, 2019, FEMA has obligated about
$487.3 million for 159 permanent work (Categories C through G) projects
in Puerto Rico. These projects focus on the restoration of disaster-
damaged infrastructure or systems.
• Category C: Roads and Bridges. FEMA obligated $140.5 million

and Puerto Rico has expended $32.8 million for 20 projects focused
on the permanent repair of roads and bridges in Puerto Rico, such as
the damage illustrated in figure 8 below.

Figure 8: Collapsed Segment of Road near Maricao, Puerto Rico, September 2018
• Category D: Water Control Facilities. As of September 30, 2019,

FEMA has obligated $435,493 for three projects, of which
approximately $150,000 has been expended. This includes work on
heavy water control infrastructure, such as berms or levees.
• Category E: Buildings and Equipment. FEMA obligated $43.5
million and Puerto Rico expended nearly $4 million for 87 projects
focused on repairing and rebuilding damaged public buildings and
equipment, such as the school shown in figure 9 below.

Figure 9: Damaged School Building in San Juan, Puerto Rico, March 2019
• Category F: Utilities. Of the $487 million FEMA obligated for

permanent work projects, the largest share, $282 million was
obligated for nine projects related to utilities, such as architectural and
engineering design services for design work for electricity grid
recovery projects. For example, in June 2019, FEMA obligated $111
million for architectural and engineering design services for design
work for electricity grid recovery projects. Puerto Rico has expended
just over $1 million of the funding obligated for projects related to
repairing utilities.
• Category G: Parks, Recreational and Other Facilities. FEMA
obligated approximately $20.9 million and Puerto Rico has expended
just over $600,000 across 40 projects focused on repairing parks,
playgrounds, and other facilities.

Appendix II: Summary of GAO’s Assessment
of the Federal Emergency Management
Agency’s (FEMA) Cost Estimating Policies and

Guidance
Agency’s (FEMA) Cost Estimating Policies

and Guidance
GAO’s Cost Estimating and Assessment Guide (GAO Cost Guide)
outlines best practices pertaining to cost estimating principles, presenting
12 steps to create high-quality estimates. 1 These steps are generally
applicable in a variety of circumstances and range from defining the
purpose of the estimate to obtaining data to presenting the estimate to
management for approval. Application of these principles should result in
reliable and valid cost estimates that management can use to make
informed decisions. To assess the extent to which FEMA’s cost
estimating policy aligns with these best practices, we compared FEMA’s
information to the GAO Cost Guide. Specifically, we reviewed FEMA
documents containing cost estimating information pertinent to Public
Assistance projects including FEMA’s Public Assistance Alternative
Procedures Guide for Permanent Work FEMA-4339-DR-PR (Alternative
Procedures Guide) and FEMA’s Cost Estimating Format (CEF) for Large
Projects Instructional Guide V2.1 (dated September 2009). We compared
FEMA’s guidance for developing cost estimates outlined in these
documents against the 12 best practices described in the GAO Cost
Guide. 2 We assessed the extent to which these documents aligned with
the best practices on a five point scale.
• Fully met. FEMA provided complete evidence that satisfies the

• Substantially met. FEMA provided evidence that satisfies a large
portion of the elements of the step.
• Partially met. FEMA provided evidence that satisfies about half of the
• Minimally met. FEMA provided evidence that satisfies a small portion
of the elements of the step.
• Not met. FEMA provided no evidence that satisfies any of the
Taken together, FEMA’s documents provided cost estimating information
that either substantially or fully meets nine of the 12 cost estimating steps.
Furthermore, the information partially met two of the 12 steps, and
minimally met one of the 12 steps. Table 1 summarizes GAO’s
1
GAO, GAO Cost Estimating and Assessment Guide Best Practices for Developing and
Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March, 2009)
2
GAO-09-3SP

Guidance
assessment of the extent to which FEMA’s information aligns with the 12

steps identified in the GAO cost guide.
Table 2: Assessment of Federal Emergency Management Agency’s (FEMA) Cost Estimating Guidance for Public Assistance
Compared to Cost Estimating Best Practices Identified in GAO’s Cost Estimating and Assessment Guide
GAO’s Assessment of
GAO’s 12 step cost FEMA’s available FEMA’s guidelines and guidance compared to GAO’s Cost Estimating and
estimating process information Assessment Guide (GAO Cost Guide)
1. Define the Fully met The purpose of a cost estimate is determined by its intended use and its
estimate’s intended use determines its scope and detail. To determine an estimate’s scope,
purpose cost analysts must identify the customer’s needs.
FEMA’s Alternative Procedures Guide and Cost Estimating Format (CEF)
describe the estimate’s purpose, level of detail required, overall scope, and
provide a timeframe for which the estimates must be developed and agreed to.
2. Develop the Substantially met An analytic approach to cost estimates typically entails a written estimating plan
estimating plan detailing a master schedule of specific tasks, responsible parties such as the
estimating team, and due dates. An estimating team should include experienced
and trained analysts. In addition, enough time should be scheduled to collect
data, including visits to contractor sites to further understand the strengths and
limitations of the data that have been collected. If the time allotted to develop the
estimate is limited, then the schedule constraint should be clearly identified in the
ground rules and assumptions, so that management understands the effect on
the estimate’s quality and confidence.
FEMA guidance describes the estimating team, cost estimating approach, roles,
and access to subject matter experts. FEMA states “highly qualified cost
estimators” will be used; however, this statement is not supported because
FEMA does not describe the level of experience nor training required of the cost
analysts. Lastly, FEMA guidance does not require the development of a master
cost schedule.
3. Define the Substantially met The key to developing a credible estimate is having an adequate understanding
program’s of the project that usually takes form in a technical baseline. A technical baseline
characteristics should include a description of the project, define the requirements, and
document the underlying technical and project assumptions necessary to
develop a cost estimate and update changes as they occur.
FEMA documentation describes a “scope of work” which provides an
understanding of the work required to repair or replace a damaged facility.
Similar to a technical baseline, the scope of work drives the cost estimate. FEMA
documentation describes who develops the scope of work, revisions, how the
scope of work informs the cost estimate, agreement to the scope, and questions
to determine if the scope of work addresses damage caused by the disaster. We
rated this step as substantially met instead of fully met because it is not evident
how the scope of work addresses acquisition strategy or risk.

Guidance
4. Determine the Fully met A work breakdown structure is the cornerstone of every project because it
estimating defines in detail the work necessary to accomplish a project’s objectives. For
structure example, a typical “work breakdown structure” reflects the requirements and
what must be accomplished to develop a project, details common elements, and
provides a basis for identifying resources and tasks for developing a project cost
estimate.
FEMA documentation describes the CEF as providing “a uniform method of
estimating costs for large projects” that “accounts for costs incurred across the
entire spectrum of eligible work (from design to project completion).” The CEF is
structured into eight parts, with each part broken down at least one level. The
CEF Guide contains definitions of each part, as well as descriptions for what is
included, how the part is calculated, and how it relates to other parts or the
scope of work. The CEF Spreadsheet’s Total Project Summary tab shows child
elements summing to the parent element, and each parent element summing to
the project total.
5. Identify ground Substantially met Cost estimates are typically based on limited information and therefore need to
rules and be bound by the constraints that make estimating possible. These constraints
assumptions are usually made in the form of assumptions. It is imperative that cost estimators
document all assumptions well and test them for risk to portray the effects of any
assumptions changing or failing, so that management fully understands the
conditions the estimate was based on. Such documentation and analysis
provides management with an invaluable perspective on its decision.
Additionally, cost estimators must ensure that assumptions are not arbitrary and
that they are founded on expert judgments rendered by experienced project and
technical personnel.
The CEF Guide provides measures to ensure assumptions are not arbitrary, are
founded on expert judgments, and are documented. However, we rated this step
as substantially met instead of fully met because the CEF Guide does not
address all GAO best practices associated with ground rules and assumptions.
For example, the CEF Guide does not discuss the level of risk if an assumption
changes or fails and its effect on the estimate, nor defines the effects of delaying
program content.
6. Obtain the Data Partially met Credible cost estimates are rooted in historical data. Estimators usually develop
estimates for new projects by relying on data from existing projects and adjusting
for any differences. Thus, collecting valid and useful historical data is a key step
in developing a sound cost estimate. One way of ensuring that the data are
applicable is to perform checks of reasonableness to see if the results are
similar.
The CEF Guide describes acceptable data that are to be used, data sources,
priority of data, evaluation of data received, and selecting the appropriate cost
data to use. FEMA has implemented a cost factor to adjust for local costs of
labor, equipment, and materials and a future price factor to adjust for expected
increases in construction costs. However, the future price curve, which FEMA
intends to take the place of the future price factor currently in place, has not yet
been finalized. Furthermore, there are several best practices in the GAO cost
guide related to data that are not included in the FEMA guidance. For example,
analyzing data for cost drivers and data normalization are not discussed.

Guidance
7. Develop the point Substantially met This step pulls all the information together to develop the point estimate. This
estimate and step includes determining the best estimating methodology, and validating the
compare to an estimate.
Independent Cost The CEF for Large Projects is a Microsoft Excel-based template used for
Estimate developing estimates for certain permanent work large projects. The CEF
Guide’s appendix E provides an overview as well as guidance on how to use the
CEF tool. We rated this step as substantially met because FEMA guidance does
not consider the following activities: expressing the point estimate in constant-
year dollars or performing cross-checks on cost drivers.
8. Conduct a Minimally met A sensitivity analysis should be included in all cost estimates because it
sensitivity examines the effects of changing assumptions and ground rules. Without a
analysis sensitivity analysis, the cost estimator will not fully understand which variable
most affects the cost estimate.
FEMA’s CEF reflects construction estimate uncertainties and includes a range of
values around estimating factors to account for contingencies. However, FEMA
guidance does not instruct estimators to perform a sensitivity analysis on cost
estimates for alternative procedures projects. A sensitivity analysis is where a
cost estimator examines the effect on the cost estimate of changing one
assumption or cost driver at a time while holding all other variables constant.
9. Conduct a risk Partially met Quantitative risk and uncertainty analysis provides a way to assess the variability
analysis in the point estimate. Having a range of costs around a point estimate is more
useful to decision makers because it conveys the level of confidence in achieving
the most likely cost and also informs them on cost, schedule, and technical risks.
Risk is accounted for in Part C of the CEF, which “reflects construction estimate
uncertainties and is designed to address budgetary risks associated with project
unknowns and complexities in determining the scope of work.” However, we
rated this step as partially met because FEMA’s guidance does not require a
statistical analysis of risks be performed to determine a range of possible costs
and the level of confidence in achieving the estimate, which are best practices
GAO has identified.
10. Document the Substantially met Documentation provides total recall of the estimate’s detail so that the estimate
estimate can be replicated by someone other than those who prepared it. Documentation
also serves as a reference to support future estimates. Documenting the cost
estimate makes available a written justification showing how it was developed
and aids in updating it as key assumptions change and more information
becomes available. According to the Cost Guide, estimates should be
documented to show all parameters, assumptions, descriptions, methods, and
the calculations used to develop the cost estimate.
FEMA guidance describes three different mechanisms for documenting the
estimate: “Complete the Project Worksheet” (PW), “CEF Project Reporting,” and
documentation within the CEF via the CEF Fact Sheet tab and the CEF Notes
tab.
The documentation contains basic information about the project and the
estimate; description of the scope of work; supporting backup information; logic,
assumptions, and reasoning for the selection of factors used; and the basis of
the CEF estimate, including source data. This step was rated as substantially
met instead of fully met because FEMA policy does not require documentation to
include a discussion of high risk areas.

Guidance
11. Present estimate Substantially met FEMA policy describes an estimate submission package for approval, to include
to Management the Excel file containing the CEF estimate, the project worksheet, and all
applicable supporting documentation. The contents of the CEF Excel file contain
the majority of items the GAO Cost Guide states are necessary for presenting
the estimate to management.
We rated this step as substantially met instead of fully met because FEMA policy
does not require the estimate submission package to contain a discussion on the
results of the third-party independent expert panel’s validation, how any
differences were resolved, nor a discussion of how the estimate was determined
to be reasonable.
12. Update the Substantially met Cost estimates should be updated whenever requirements change and the
estimate results should be reconciled and recorded against the old estimate baseline. The
documented comparison between the current estimate (updated with actual
costs) and the old estimate allows the cost estimator to determine the level of
variance between the two estimates. In other words, it allows estimators to see
how well they are estimating and how the project is changing over time.
Step 7 of the Cost Estimating Format Development Process is “CEF Project
Reporting,” during which the CEF “will be revised periodically, as data from
actual projects become available” and will occur on an as-needed basis.
However, we rated this step as substantially met instead of fully met because
FEMA policy does not explain how actual costs, technical, and schedule data are
archived for future use.
Source: GAO analysis of Federal Emergency Management Agency Documents | GAO-20-221
Note: Our assessments of FEMA’s cost estimating guidance in comparison with the GAO Cost
Estimating and Assessment Guide (GAO-09-03SP) fall in the following categories:
Fully met: FEMA provided complete evidence that satisfies the elements of the step;
Substantially met: FEMA provided evidence that satisfies a large portion of the elements of the step;
Partially met: FEMA provided evidence that satisfies about half of the elements of the step;
Minimally met: FEMA provided evidence that satisfies a small portion of the elements of the step; and
Not met: FEMA provided no evidence that satisfies any of the elements of the step.

Appendix III: Comments from the
Appendix III: Comments from the Department
of Homeland Security
Department of Homeland Security




Appendix IV: Comments from the
Commonwealth of Puerto Rico


Appendix V: GAO Contact and Staff
Appendix V: GAO Contact and Staff
Acknowledgments
Acknowledgments
Chris Currie, (404) 679-1875 or curriec@gao.gov.

GAO Contact
In addition to the contact named above, Joel Aldape (Assistant Director),
Staff Taylor Hadfield (Analyst in Charge), Michelle Bacon, Brian Bothwell,
Acknowledgments Lorraine Ettaro, Eric Hauswirth, Heidi Nielson, Danielle Pakdaman,
Amanda Prichard, Kevin Reeves, and Mary Weiland made key
contributions to this report.

GAO Related Products
U.S. Virgin Islands Recovery: Additional Actions Could Strengthen

FEMA’s Key Disaster Recovery Efforts. GAO-20-54. Washington, D.C.:
November 19, 2019.
Disaster Resilience Framework: Principles for Analyzing Federal Efforts

to Facilitate and Promote Resilience to Natural Disasters.
GAO-20-100SP. Washington, D.C.: October 23, 2019.
Disaster Recovery: Recent Disasters Highlight Progress and Challenges.

GAO-20-183T. Washington, D.C.: October 22, 2019.
Wildfire Disasters: FEMA Could Take Additional Actions to Address

Unique Response and Recovery Challenges. GAO-20-5. Washington,
D.C.: October 9, 2019.
Puerto Rico Electricity Grid Recovery: Better Information and Enhanced

Coordination Is Needed to Address Challenges. GAO-20-141.
Washington, D.C.: October 8, 2019.
Emergency Management: FEMA’s Disaster Recovery Efforts in Puerto

Rico and the U.S. Virgin Islands. GAO-19-662T. Washington, D.C.: July
11, 2019.
2017 Disaster Relief Oversight: Strategy Needed to Ensure Agencies’

Internal Control Plans Provide Sufficient Information. GAO-19-479.
Washington, D.C.: June 28, 2019.
Emergency Management: FEMA Has Made Progress, but Challenges

and Future Risks Highlight Imperative for Further Improvements.
GAO-19-617T . Washington, D.C.: June 25, 2019.
Emergency Management: FEMA Has Made Progress, but Challenges

and Future Risks Highlight the Imperative for Further Improvements.
GAO-19-594T. Washington, D.C.: June 12, 2019.
Disaster Assistance: FEMA Action Needed to Better Support Individuals

Who Are Older or Have Disabilities. GAO-19-318. Washington, D.C.: May
14, 2019.
Disaster Contracting: Actions Needed to Improve the Use of Post-

Disaster Contracts to Support Response and Recovery, GAO-19-281.
Washington, D.C.: April 24, 2019.

2017 Hurricane Season: Federal Support for Electricity Grid Restoration

in the U.S. Virgin Islands and Puerto Rico. GAO-19-296. Washington,
D.C.: April 18, 2019.
FEMA Grants Modernization: Improvements Needed to Strengthen

Program Management and Cybersecurity. GAO-19-164. Washington,
D.C.: April 9, 2019.
Disaster Recovery: Better Monitoring of Block Grant Funds Is Needed.

GAO-19-232. Washington, D.C.: March 25, 2019.
Puerto Rico Hurricanes: Status of FEMA Funding, Oversight, and

Recovery Challenges. GAO-19-256. Washington, D.C.: March 14, 2019.
Huracanes de Puerto Rico: Estado de Financiamiento de FEMA,

Supervisión y Desafíos de Recuperación. GAO-19-331. Washington,
D.C.: March 14, 2019.
High-Risk Series: Substantial Efforts Needed to Achieve Greater

Progress on High-Risk Areas. GAO-19-157SP. Washington, D.C.: March
6, 2019.
U.S. Virgin Islands Recovery: Status of FEMA Public Assistance Funding

and Implementation. GAO-19-253. Washington, D.C.: February 25, 2019.
2017 Disaster Contracting: Action Needed to Better Ensure More

Effective Use and Management of Advance Contracts. GAO-19-93.
Washington, D.C.: December 6, 2018.
Continuity of Operations: Actions Needed to Strengthen FEMA’s

Oversight and Coordination of Executive Branch Readiness.
GAO-19-18SU. Washington, D.C.: November 26, 2018.
Homeland Security Grant Program: Additional Actions Could Further

Enhance FEMA’s Risk-Based Grant Assessment Model. GAO-18-354.
Washington, D.C.: September 6, 2018.
2017 Hurricanes and Wildfires: Initial Observations on the Federal

Response and Key Recovery Challenges. GAO-18-472. Washington,
D.C.: September 4, 2018.

Federal Disaster Assistance: Individual Assistance Requests Often

Granted but FEMA Could Better Document Factors Considered.
GAO-18-366. Washington, D.C.: May 31, 2018.
2017 Disaster Contracting: Observations on Federal Contracting for

Response and Recovery Efforts. GAO-18-335. Washington, D.C.:
February 28, 2018.
Disaster Recovery: Additional Actions Would Improve Data Quality and

Timeliness of FEMA’s Public Assistance Appeals Processing.
GAO-18-143. Washington, D.C.: December 15, 2017.
Disaster Assistance: Opportunities to Enhance Implementation of the

Redesigned Public Assistance Grant Program. GAO-18-30. Washington,
D.C.: November 8, 2017.
Climate Change: Information on Potential Economic Effects Could Help

Guide Federal Efforts to Reduce Fiscal Exposure. GAO-17-720.
Washington, D.C.: September 28, 2017.
Federal Disaster Assistance: Federal Departments and Agencies

Obligated at Least $277.6 Billion during Fiscal Years 2005 through 2014.
GAO-16-797. Washington, D.C.: September 22, 2016.
Disaster Recovery: FEMA Needs to Assess Its Effectiveness in

Implementing the National Disaster Recovery Framework. GAO-16-476.
Washington, D.C.: May 26, 2016.
Disaster Response: FEMA Has Made Progress Implementing Key

Programs, but Opportunities for Improvement Exist. GAO-16-87.
Washington, D.C.: February 5, 2016.
Hurricane Sandy: An Investment Strategy Could Help the Federal

Government Enhance National Resilience for Future Disasters.
GAO-15-515. Washington, D.C.: July 30, 2015.
Budgeting for Disasters: Approaches to Budgeting for Disasters in

Selected States. GAO-15-424. Washington, D.C.: March 26, 2015.
High-Risk Series: An Update. GAO-15-290. Washington, D.C.: February

11, 2015.

Emergency Preparedness: Opportunities Exist to Strengthen Interagency

Assessments and Accountability for Closing Capability Gaps. GAO-15-20.
Washington, D.C.: December 4, 2014.
Fiscal Exposures: Improving Cost Recognition in the Federal Budget.

GAO-14-28. Washington, D.C.: October 29, 2013.
Federal Disaster Assistance: Improved Criteria Needed to Assess a

Jurisdiction’s Capability to Respond and Recover on Its Own.
GAO-12-838. Washington, D.C.: September 12, 2012.
(102654)
The Government Accountability Office, the audit, evaluation, and investigative
GAO’s Mission arm of Congress, exists to support Congress in meeting its constitutional
responsibilities and to help improve the performance and accountability of the
federal government for the American people. GAO examines the use of public
funds; evaluates federal programs and policies; and provides analyses,
recommendations, and other assistance to help Congress make informed
oversight, policy, and funding decisions. GAO’s commitment to good government
is reflected in its core values of accountability, integrity, and reliability.
The fastest and easiest way to obtain copies of GAO documents at no cost is
Obtaining Copies of through our website. Each weekday afternoon, GAO posts on its website newly
GAO Reports and released reports, testimony, and correspondence. You can also subscribe to
GAO’s email updates to receive notification of newly posted products.
Testimony
Order by Phone The price of each GAO publication reflects GAO’s actual cost of production and
distribution and depends on the number of pages in the publication and whether
the publication is printed in color or black and white. Pricing and ordering
information is posted on GAO’s website, https://www.gao.gov/ordering.htm.
Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537.
Orders may be paid for using American Express, Discover Card, MasterCard,
Visa, check, or money order. Call for additional information.
Connect with GAO on Facebook, Flickr, Twitter, and YouTube.

Connect with GAO Subscribe to our RSS Feeds or Email Updates. Listen to our Podcasts.
Visit GAO on the web at https://www.gao.gov.
Contact FraudNet:
To Report Fraud,
Website: https://www.gao.gov/fraudnet/fraudnet.htm
Waste, and Abuse in
Automated answering system: (800) 424-5454 or (202) 512-7700
Federal Programs
Orice Williams Brown, Managing Director, WilliamsO@gao.gov, (202) 512-4400,
Congressional U.S. Government Accountability Office, 441 G Street NW, Room 7125,
Relations Washington, DC 20548
Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

Public Affairs U.S. Government Accountability Office, 441 G Street NW, Room 7149
Washington, DC 20548
James-Christian Blockwood, Managing Director, spel@gao.gov, (202) 512-4707

Strategic Planning and U.S. Government Accountability Office, 441 G Street NW, Room 7814,
External Liaison Washington, DC 20548
Please Print on Recycled Paper.

Informe de GAO Sobre La Asistencia de FEMA Tras Los Huracanes Irma y María

Caricato da

Informazioni sul documento

Titolo originale

Copyright

Formati disponibili

Condividi questo documento

Condividi o incorpora il documento

Opzioni di condivisione

Hai trovato utile questo documento?

Questo contenuto è inappropriato?

Copyright:

Formati disponibili

Informe de GAO Sobre La Asistencia de FEMA Tras Los Huracanes Irma y María

Caricato da

Copyright:

Formati disponibili

United States Government Accountability Office

Report to Congressional Requesters

PUERTO RICO DISASTER RECOVERY

Why GAO Did This Study What GAO Found

United States Government Accountability Office

Appendix I The Status of Public Assistance Program Funding in Puerto Rico 40

Appendix II Summary of GAO’s Assessment of the Federal Emergency

Appendix III Comments from the Department of Homeland Security 49

Appendix IV Comments from the Commonwealth of Puerto Rico 53

Appendix V GAO Contact and Staff Acknowledgments 55

GAO Related Products 56

Page i GAO-20-221 Puerto Rico Disaster Recovery

Page ii GAO-20-221 Puerto Rico Disaster Recovery

Central Recovery Office Central Office for Recovery, Reconstruction,

Page iii GAO-20-221 Puerto Rico Disaster Recovery

441 G St. N.W.

In a span of 14 days in September 2017, two major hurricanes—Irma and

The Federal Emergency Management Agency (FEMA)—a component of

Page 1 GAO-20-221 Puerto Rico Disaster Recovery

We have previously reported on federal disaster response and recovery

You asked us to review the federal government’s response and recovery

Page 2 GAO-20-221 Puerto Rico Disaster Recovery

To address these objectives, we reviewed relevant laws and FEMA Public

To assess the status of Public Assistance program funding in Puerto

Page 3 GAO-20-221 Puerto Rico Disaster Recovery

To examine the extent to which Public Assistance cost estimating

Page 4 GAO-20-221 Puerto Rico Disaster Recovery

To assess the extent to which FEMA has developed policies and

Page 5 GAO-20-221 Puerto Rico Disaster Recovery

To describe the structures FEMA and Puerto Rico have created to

We conducted this performance audit from March 2018 through January

On September 6, 2017, the eye of Hurricane Irma traveled about 50

Page 6 GAO-20-221 Puerto Rico Disaster Recovery

Figure 1: The Paths of Hurricanes Irma and Maria

In response to the request of the governor of Puerto Rico, the president

Page 7 GAO-20-221 Puerto Rico Disaster Recovery

Page 8 GAO-20-221 Puerto Rico Disaster Recovery

Page 9 GAO-20-221 Puerto Rico Disaster Recovery

FEMA. FEMA administers the Public Assistance program in partnership

Puerto Rico Central Office of Recovery, Reconstruction and

Page 10 GAO-20-221 Puerto Rico Disaster Recovery

Commonwealth agencies, local entities, and private non-profits.

To develop projects under the Public Assistance program, FEMA and

Page 11 GAO-20-221 Puerto Rico Disaster Recovery

Page 12 GAO-20-221 Puerto Rico Disaster Recovery

Page 13 GAO-20-221 Puerto Rico Disaster Recovery

Page 14 GAO-20-221 Puerto Rico Disaster Recovery

Page 15 GAO-20-221 Puerto Rico Disaster Recovery

Obligated amount Expended amount Percent

The majority of FEMA’s obligations and the funding Puerto Rico

Page 16 GAO-20-221 Puerto Rico Disaster Recovery

Delays in establishing cost estimating guidance. Given the

Page 17 GAO-20-221 Puerto Rico Disaster Recovery

Large number of damaged sites requiring a fixed cost estimate. In

Page 18 GAO-20-221 Puerto Rico Disaster Recovery

Implementation challenges with Section 20601 of the Bipartisan

We will continue to monitor the status of FEMA’s cost estimating process,

Page 19 GAO-20-221 Puerto Rico Disaster Recovery

FEMA Has Adapted

• Cost Factor: According to FEMA officials, during the development of

Page 20 GAO-20-221 Puerto Rico Disaster Recovery

Page 21 GAO-20-221 Puerto Rico Disaster Recovery

Figure 7: GAO Assessment of Federal Emergency Management Agency (FEMA)